Case Digest (G.R. No. 65017)
Facts:
In People of the Philippines vs. Stalin Guevarra y Papasin, G.R. No. 65017 decided on November 13, 1989 under the 1987 Constitution, the accused-appellant, Stalin Guevarra, was arraigned before the Court of First Instance of Oriental Mindoro for the murder of Joselito de los Reyes. On November 29, 1980 at around midnight, de los Reyes, a 23-year-old security guard, and his companions were returning from a barangay high school dance in San Agustin II, Naujan. Appellant, then 27 and drinking in the barrio, suddenly emerged with his cohort, Eduardo Romero (at large), waylaid the group along a rocky path. While Romero stabbed de los Reyes just below the navel with a sharp instrument, Guevarra embraced and immobilized the victim from behind, enabling the fatal thrust. The victim bled to death in a local clinic. Eyewitnesses Teofilo Martinez, Rosabel Magno, and Babylyn Martinez positively identified Guevarra at the crime scene by flashlight illumination. Guevarra was arrested hours laCase Digest (G.R. No. 65017)
Facts:
- Proceedings and Parties
- Stalin Guevarra was charged by information with murder under Article 248 of the Revised Penal Code for the stabbing death of Joselito de los Reyes on November 29, 1980 in Barangay San Agustin II, Naujan, Oriental Mindoro.
- The trial court (Court of First Instance) found Guevarra guilty and imposed an indeterminate sentence of 10 years and 1 day to 17 years and 4 months’ imprisonment, plus civil indemnity and other penalties.
- On appeal, the Intermediate Appellate Court increased the penalty to reclusion perpetua, increased indemnity to ₱12,000, and certified the case to the Supreme Court due to the capital nature of the offense.
- Events Leading to the Killing
- At around midnight after a school-sponsored dance, the victim Joselito de los Reyes walked home with companions Teofilo Martinez, Rosabel Magno, and Babylyn Martinez. Teofilo carried a flashlight.
- The assailants, Guevarra (27 years old) and Eduardo Romero (still at large), suddenly appeared. Guevarra embraced Joselito from behind, immobilizing him; Romero then stabbed Joselito below the navel with a sharp-bladed instrument.
- The assailants fled toward San Agustin; the beam from the flashlight allowed all three companions to clearly identify Guevarra and Romero as the attackers.
- Post-Crime Investigation and Medical Findings
- The victim, still alive, was brought first to the Naujan Police Station and then to Dr. Nicolás B. Balbin’s clinic, but died of intra-abdominal hemorrhage. Post-mortem confirmed a fatal stab wound likely from a “balisong.”
- Police found Guevarra later that night at his home, drunk and eating bananas; Romero remained at large. Guevarra was arrested and the case was tried on information alleging murder qualified by treachery, evident premeditation, superior strength, and nocturnity.
Issues:
- Whether Guevarra is criminally liable as a principal by indispensable cooperation for the murder of Joselito de los Reyes.
- Whether the circumstances of treachery and evident premeditation were properly established.
- Whether Guevarra’s defenses—alibi and alleged variance between the information and proof—create reasonable doubt.
- Whether flight and post-offense conduct support a finding of guilty mind.
- What penalty and civil indemnity should be imposed.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)