Case Digest (G.R. No. L-35099)
Facts:
The People of the Philippines v. Manuel Dimatulac Alias Commander Ligaya, Fernando Borja Alias Fer Alias Bansot, Reynaldo Galang Alias Ireng, and Gaudencio Maliwat Alias Guding, G.R. No. L-35099, May 03, 1983, the Supreme Court En Banc, Relova, J., writing for the Court.The prosecution (the People of the Philippines) filed an amended information (February 2, 1971) in the Court of First Instance of Tarlac (Criminal Case No. 167) charging Manuel Dimatulac (alias Commander Ligaya), Fernando Borja (alias Fer), Reynaldo Galang (alias Ireng) and Gaudencio Maliwat (alias Guding) with murder and frustrated murder for acts on the night of June 28, 1968, in San Miguel, Tarlac. The information alleged that the accused, with others, surrounded the hut of brothers Alfredo and Carlos Balanditan, tied and beat them, that Dimatulac fired a gun at Alfredo, and that Carlos sustained fatal neck wounds inflicted by another member of the group.
At trial the principal witnesses for the People were Alfredo Balanditan (surviving victim), Adriano Gomez (who escorted the assailants to the hut and witnessed events), Dr. Segundino Fausto (who examined Alfredo), and Dr. Alipio Salanga (who performed the post-mortem on Carlos). Their testimony established that the attack occurred between 8 and 9 p.m., that a kerosene lamp and nearby electric bulbs allowed Alfredo to identify his assailants (naming Dimatulac, Borja, Maliwat, Galang and others), that the brothers were tied and beaten, that Dimatulac fired at Alfredo and that Bondoc cut Carlos’ neck, resulting in death. Alfredo sustained several nonfatal lacerations and was hospitalized.
The accused pleaded not guilty. Dimatulac asserted an alibi: he claimed sickness and confinement in his house from June 17 to July 5, 1968, supported by testimony from Dr. Elisa Rosales‑Cura, her attendant Rosita Fernandez, his wife Ines Arceo, Barangay Captain Jose Borja, and a relative of Fernando Borja. During the trial, Gaudencio Maliwat died and the case against him was dismissed (order of January 17, 1972). Reynaldo Galang did not appeal his conviction. Fernando Borja filed a motion to withdraw his appeal, which the Court granted on November 10, 1977, leaving Manuel Dimatulac as the sole appellant before the Supreme Court.
The Court of First Instance convicted Dimatulac and Borja (and Galang) — finding Dimatulac guilty as principal and sentencing him to death with civil indemnities, and finding Borja and Galang guil...(Subscriber-Only)
Issues:
- Was the conviction of Manuel Dimatulac for murder (and of his co-accused for accomplice liability) supported by evidence beyond reasonable doubt?
- If guilty, was imposition of the death penalty proper...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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