G.R. No. L-23514 - People vs. Masala, Jr.

The case involves the People of the Philippines as Plaintiff-Appellee and the defendants Avelino Manansala, Jr. and Jose Manansala as Defendants-Appellants.
It is an appeal from the decision of the Court of First Instance of Albay in Criminal Case No. 3285, where both accused were convicted of murder.

The fatal incident occurred on March 27, 1962, between 1:00 and 2:00 o’clock in the afternoon.
The events took place at the New Bicol Carinderia, an eatery located near the Legaspi Port Market in Legaspi City.

A quarrel erupted inside the carinderia when Rodrigo Aringo (alias Diego), a baggage boy, confronted Avelino Manansala, Jr. over a disputed baggage fee.
According to the prosecution's account, after the altercation began:

Avelino initially responded to Rodrigo’s aggression by evading blows until a weapon (a balisong or Batangas knife) came into play.
Jose Manansala, an uncle of Avelino, was present and, after noticing the commotion while loading baggage nearby, intervened by embracing Rodrigo from behind.
While Rodrigo was held in a tight embrace by Jose, Avelino proceeded to stab Rodrigo repeatedly.
Rodrigo's body, found on a bamboo bed (papag), bore thirteen stab wounds inflicted in the chest, abdomen, back, and extremities.

Prosecution relied on the testimonies of eyewitnesses Celestino Atun and Percival Amador, as well as the account of policemen who arrived at the scene.
Two additional defense witnesses, Domingo Daria and Salvador Petilos, testified on the sequence of events although their accounts aimed to support a claim of self-defense.

An autopsy by Dr. Antolin Lotivio confirmed that the victim died from massive hemorrhage and shock due to multiple wounds.
The forensic evidence substantiated that the wounds were inflicted while the victim was in a helpless, prone position.

The defense claimed that Rodrigo was armed and had attempted to stab Avelino with a knife.
However, evidence contradicts this assertion since:

Avelino had not suffered any knife wound.
None of the policemen saw Rodrigo wielding or presenting a knife.
Avelino’s decision to remain silent upon surrender further undermined his self-defense claim.

Avelino Manansala, Jr. and his uncle, Jose Manansala, were implicated in the murder of Rodrigo Aringo.
While both were found guilty, the trial court recognized mitigating circumstances (sufficient provocation) for Avelino but held Jose partially liable for his contributory actions after the first knife thrust.

Whether Avelino’s plea of self-defense is tenable given the discrepancies between his defense and the factual evidence.
The absence of any physical evidence (such as a knife wound on Avelino) to support the claim that he was attacked by an armed victim.

Whether the victim’s initial act of assault (a fist blow and provocation) justifies a mitigating circumstance in Avelino’s case.
The sufficiency of the provocation evidence in reducing the severity of Avelino's penalty.

Whether Jose’s active participation—specifically, his physical intervention and subsequent actions—constitutes accomplice liability.
The extent to which his actions, although not the primary cause of the stabbing, contributed to the commission of the crime.

Whether the imposed penalty falls within the permissible range under the Indeterminate Sentence Law.
The correctness of the penalty range given the mitigating and aggravating circumstances present in the case.