Title
People vs. Machete
Case
G.R. No. 103287-88
Decision Date
Mar 14, 1994
Two police officers providing security at a public dance were disarmed and attacked; one officer was killed. The shooter was convicted of homicide, not murder, due to insufficient evidence of treachery.

Case Digest (G.R. No. 103287-88)
Expanded Legal Reasoning Model

Facts:

  • Parties and Charges
    • The case involves:
      • Appellant Ronilo Machete, also known as "Pawe," who was prosecuted.
      • His cousin, Rene O. Machete, known as "Eboy," who was charged as a co-accused but managed to evade arrest.
    • Charges were filed in three separate informations:
      • Criminal Case No. N-1468 – charged with murder with assault upon a person in authority for the killing of Patrolman (Pat.) Panfilo Mendoza, in addition to attacking Pat. Leonilo Maranga.
      • Criminal Case No. N-1469 – charged with the attempted murder of Juanito Narrido, who sustained gunshot wounds during the same incident.
      • Criminal Case No. N-1470 – charged with attempted murder in connection with gunshot wounds inflicted upon Elmeo Sabah during the events that unfolded.
  • Overview of the Incident
    • On January 20, 1987:
      • Pat. Maranga and Pat. Mendoza were assigned as security officers at a public benefit dance held in Sitio Bigaa, Barangay San Pablo, Naval, Leyte.
      • They arrived at the dance venue at about 8:45 p.m. and set up at a travelling store operated by Maria Juanes, where they accepted coffee served by her.
    • The sequence of events as narrated by the prosecution:
      • Ronilo Machete approached the two patrolling officers from behind.
      • He seized the armalite rifle from Pat. Mendoza and then pointed it at Pat. Maranga.
      • Concurrently, Rene Machete took possession of Pat. Maranga’s rifle.
      • As Pat. Mendoza attempted to retrieve his armament, Ronilo fired several shots, fatally wounding him.
      • During the ensuing chaos, gunfire also wounded Juanito Narrido.
      • After the incident, both accused fled, taking away the police officers’ rifles.
    • Post-Incident Developments:
      • The body of Pat. Mendoza was transported to the district hospital of Naval, where a medical examination revealed six gunshot wounds, with two clearly inflicted while the victim was recumbent.
      • Ronilo Machete later confessed, with his testimony largely contending that it was his cousin Rene who fired the fatal shots, a claim further corroborated by defense witnesses.
  • Trial Proceedings and Testimonies
    • At arraignment, Ronilo pleaded not guilty to all charges in the three informations.
    • During the joint trial:
      • Prosecution evidence was principally based on the testimonies of Pat. Maranga and Juanito Narrido, who affirmed that Ronilo fired the shots.
      • Defense witnesses, including Antonio Juntilla and Julianita Juanes, provided accounts that partly supported Ronilo’s narrative, attributing the fatal shot to Rene Machete.
    • Conflicting Versions:
      • Prosecution witnesses testified that Ronilo Machete directly shot Pat. Mendoza.
      • Ronilo’s account, along with the testimonies of his defense witnesses, maintained that it was actually Rene Machete who was responsible.
    • The trial court ultimately convicted Ronilo Machete:
      • Found him guilty beyond reasonable doubt for murder (in Criminal Case No. N-1468) and for serious physical injuries (in Criminal Case No. N-1469).
      • Acquitted him in Criminal Case No. N-1470 for insufficiency of evidence.
      • Imposed corresponding penalties, including reclusion perpetua for murder and an indeterminate sentence for serious physical injuries.
    • Appellant’s Post-Trial Arguments:
      • Ronilo Machete appealed on the ground that the trial court erred in evaluating the credibility of the witnesses.
      • He questioned the finding of treachery as a qualifying circumstance for murder, asserting that the circumstances did not support such an aggravation.

Issues:

  • Sufficiency and Credibility of Evidence
    • Whether the trial court erred in giving preferential weight to the testimony of the prosecution witnesses over that of the defense witnesses.
    • Whether the conflicting accounts regarding who fired the fatal shots (Ronilo versus Rene) were adequately assessed.
  • Qualification of the Crime
    • Whether the shooting of Pat. Mendoza constituted murder by virtue of treachery.
      • The prosecution maintained that the act was treacherous, leaving the victim with no chance to defend himself.
      • The defense, supported by the Solicitor General’s arguments, contended that the shooting was not executed in a manner that could be deemed treacherous.
    • Whether the presence or absence of treachery should rightly lead to a conviction for murder as opposed to homicide.
  • Impact of Defendant’s Conduct
    • Whether Ronilo Machete’s post-incident actions, including fleeing to Malangas, justify an inference of guilt.
    • The relevance of his delay in apprehension (four years after the crime) in assessing his criminal intent and behavior.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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