Facts:

• The case involves The People of the Philippines vs. Rosalino Macandili (alias Douglas) and Moises Roque, charged with murder.
• The incident took place on July 11, 1939, in Malolos, Bulacan.
• The defendants confronted the victim, Lucio V. Crisostomo, demanding money for cigarettes.
• Upon Crisostomo's refusal, the defendants attacked him.
• Rosalino Macandili initiated the assault with a knife, leading to a struggle for the weapon.
• During the struggle, Macandili passed the knife to Moises Roque, who threatened Crisostomo into surrendering a balisong.
• Under duress, Crisostomo complied, making him vulnerable to multiple stabbings by Roque.
• Crisostomo died from his injuries three days later.
• The trial court found both defendants guilty of murder, qualified by treachery, with recidivism as an aggravating circumstance and nonhabitual intoxication as a mitigating factor.
• Each defendant was sentenced to reclusion perpetua, ordered to indemnify the victim's heirs P2,000, and to pay trial costs.
• The defendants appealed, questioning the validity of the ante-mortem declarations and the sufficiency of the evidence.

Issue:

• (Unlock)

Ruling:

• The Supreme Court affirmed the lower court's judgment.
• The ante-mortem declarations of the deceased were deemed admissible.
• The evidence presented by the prosecu...(Unlock)

Ratio:

• The Court ruled that Crisostomo's ante-mortem declarations were admissible as they were made with awareness of his impending death, fulfilling the criteria for dying declarations.
• Testimony from a police officer who arrested Roque, along with the nature of Crisostomo's injuries, indicated he was in a state of "articulo mortis" when he ma...continue reading