Case Digest (G.R. No. L-27938)
Facts:
The People of the Philippines v. Venancio Malilay, et al., G.R. No. L-27938, April 22, 1975, Supreme Court Second Division, Fernando, J., writing for the Court. The plaintiff-appellee was the People of the Philippines; the defendants-appellants were Venancio Malilay, Carlos Guieb, Camilo Melchor, and Santos Manguba (two other accused, Domingo Pineda and Jose Sarmiento, were mentioned: Pineda died during the trial and Sarmiento was at large).
On May 9, 1961 the victim, Ceferino Cases, accompanied by his herdsman Moises Rivera, Jr., went to mark a parcel of land in Tanyag that both Cases and appellant Malilay claimed. The confrontation occurred at the house of Agustin Sumajit. Appellant Malilay engaged Cases in angry words and then forcibly grabbed him; Cases fell face down. According to eyewitnesses Rivera and Sumajit, Malilay and the other appellants and companions (including Pineda and Sarmiento) then attacked Cases repeatedly with a hammer, crowbar and bolo until he died of head injuries and hemorrhage. Rivera testified that after the assault Malilay threatened him and attempted to pursue him with a bolo; Rivera also had earlier, three days after the killing, subscribed to an extrajudicial affidavit claiming he only heard of Cases' death but later explained in court that he signed it out of fear of Malilay.
The trial court found the four appellants guilty of murder and, on September 6, 1968, sentenced each to reclusion perpetua and ordered each to indemnify the heirs in P6,000. The defendants appealed, asserting primarily that the prosecution failed to overcome the constitutional presumption of innocence, that their alibi defenses were proved, and (as to Guieb and Melchor) that no conspiracy had been proven. The Supreme Court, in the Sec...(Subscriber-Only)
Issues:
- Was the constitutional presumption of innocence overcome such that appellants' guilt was proved beyond reasonable doubt?
- Were the appellants' assertions of alibi sufficiently established to merit acquittal?
- Was there sufficient proof of conspiracy or concerted action to hold appellants Carlos Guieb and Camilo Melchor crimi...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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