G.R. No. L-35700 - People vs. Geronimo

On April 6, 1966, at about 12:30 p.m. in Sitio Ilaya, Poblacion Norte, Sigma, Capiz, the events unfolded in a tuba store where the accused and the victim, Fermin Magbanua, were drinking.
The accused-appellants were Enrico Geronimo, Romeo Geronimo, and Jose Geronimo; Enrico is the uncle of Romeo and Jose, who are brothers. Fermin Magbanua, the deceased, was a first cousin of Romeo and Jose and a nephew of Enrico.
Prior to the killing, the amended information for Murder also included two additional accused—Isidro Geronimo and Eleodoro Carlos—though these individuals were not apprehended.

After drinking tuba at a local store, the group left the premises. At a point several meters from the store, the victim was first hit on the face by a sling shot wielded by Eleodoro Carlos.
As Fermin Magbanua fell to the ground, Romeo Geronimo ran to assist by holding the victim, while Jose Geronimo went around and struck him on the head with a stone, rendering him unconscious.
With Fermin immobilized, Enrico Geronimo took the bolo from the victim’s waist, hacking him on the right ankle joint. Subsequently, Jose Geronimo again used a bolo to strike the left ankle joint, almost severing it.
Fermin Magbanua eventually died from the injuries sustained, which were later supported by a medical certificate detailing multiple wounds including incised lacerations and a severed tendon.

The prosecution relied on eyewitness testimonies of Bonifacio Bacalangco and Teresita Delfin.
The ante-mortem declaration of the victim explicitly named Enrico, Romeo, and Jose Geronimo as his assailants.
Medical evidence corroborated the nature and location of the wounds, highlighting severe incised wounds on the posterior aspects of both ankles and additional injuries.

Enrico Geronimo, pleading guilty, maintained that he alone inflicted the fatal injuries.
Romeo and Jose Geronimo denied direct participation in the crime and claimed that Romeo, in fact, acted to help by holding the victim.

Additional witness statements from police and other individuals (Consolacion Banjao and Enrico de la Cruz) supported the account that implicated all the accused to varying degrees.

At trial, Enrico Geronimo pleaded guilty and was sentenced to an indeterminate penalty ranging from six (6) to twelve (12) years, with additional indemnification and costs imposed.
The Court of First Instance of Capiz convicted Romeo and Jose Geronimo beyond reasonable doubt of murder, basing their decision largely on:

Romeo Geronimo was found guilty as his act of holding the victim, which facilitated the lethal blows delivered by his accomplice, was sufficient to impute complicity.
Jose Geronimo’s active participation in striking the victim further consolidated his guilt.

Whether the trial court erred in convicting Romeo and Jose Geronimo of conspiracy with Enrico Geronimo in killing the deceased.

Argument from appellants: No clear evidence of an agreement or premeditated design was provided, as the aggression was spontaneous.

Whether the convictions were based on testimonies that were allegedly unbelievable and unworthy of credence.

Challenge to the reliability of eyewitness affidavits, which the defense argued were influenced by external factors.

Whether the evidence supports convicting Romeo Geronimo despite his claimed minimal participation (merely holding the victim and not directly engaging in the aggression).
Whether the crime committed should be classified as murder (with qualifying circumstances such as treachery) instead of homicide.

Appellants asserted that the killing resulted from a sudden outburst rather than premeditated treachery.

Whether mitigating circumstances, specifically "lack of intent to commit so grave a wrong" (and for Romeo, possibly "lack of instruction"), should have been credited in reducing the criminal liability or penalty imposed.