G.R. No. 45450 - People vs. Masin

The accused – Getulio Masin, Jose Tongol, Alejandro Laina, Simeon Aranas, Ambrosio Mabascug, Basilio Mangao, and Cirilo Aboabo – were motivated by a superstition that witchcraft and witcheries still existed.
They harbored the unfounded belief that Santiago Vite and Isabel Taal, along with their family, were witches responsible for the death of Fermin Pabatan (the husband of accused Petra Tocmo) in Bohol.
The accused’s ideological and irrational adherence to witchcraft superstitions served as the basis for their conspiracy against the Vite family.

On December 22, 1935, the accused gathered at Marciano Mangao’s residence in the barrio of Map-an, Jimenez, Occidental Misamis, where they drank “tuba” and reaffirmed their intention to rid their barrio of the alleged witches.
During the meeting, Getulio Masin and co-accused discussed using fire as the method to eliminate the Vite family and procured a can of gasoline for the purpose.
The accused, some armed with bolos, others with iron bars and sticks, proceeded to the house where the Vite family resided.
They set fire to the dwelling by ordering Vicencio Jabla to both ignite and spill the gasoline, thereby ensuring a rapid conflagration.
As the household caught fire, the residents attempted to escape by jumping from the window.

The nine-year-old Bonifacia Vite was thrown, alive, into the flames—with repeated attempts being made to keep her in the fire even though she initially managed to get free.
Both Isabel Taal and Santiago Vite, in their desperate bid to escape, were assaulted with iron bars and sticks; Santiago Vite was further beaten while already on the ground.

The triple murder was thus carried out in a manner that involved both arson and blunt force, evidencing clear premeditation and brutality.

The crime was discovered the following day when authorities, arriving at the scene, found the burnt and mutilated bodies of Isabel Taal and Bonifacia Vite within the remains of the house.
Santiago Vite’s body was found beneath a remnant of the eaves, accompanied by his bamboo internode tool.
Detailed autopsy reports by Dr. Jose Contreras revealed multiple fractures and burns, which substantiated the violent means by which the victims were killed.

The male victim (Santiago Vite) exhibited extensive cranial and facial fractures from blunt force trauma.
The female victim (Isabel Taal) had severe cranial fractures with corroborative signs of blunt force.
The child’s body (Bonifacia Vite) showed that she was completely burned, making external lesions hard to identify.

The accused were charged with triple murder in a single information filed on January 10, 1936, in the Court of First Instance of Occidental Misamis.
Despite a petition for dismissal by the defense of accused Petra Tocmo on grounds of lack of evidence, the remaining accused were convicted of the three murders.

Getulio Masin was sentenced to reclusion perpetua with corresponding accessory penalties.
The other six were condemned to seventeen years, four months, and one day of reclusion temporal along with accessory penalties.

All the accused were additionally ordered to indemnify the heirs of the deceased with a sum of P1,000 each, jointly and severally.

The testimonies of two prosecution witnesses, Vicencio Jabla and Marciano Mangao, played a central role in establishing that:

Prior discussions among the accused confirmed the intent to murder the Vite family based on their superstition.
The accused actively participated in the execution of the crime, including the setting of the fire and the beating of the victims.

Testimonies from the accused corroborated the presence of the conspirators at the scene of the execution, with admissions that aligned with key elements of the prosecution’s evidence.
Corroborative autopsy findings reinforced the witness accounts by providing a forensic basis for the brutal injuries inflicted on the victims.

Whether the testimony of prosecution witnesses (Vicencio Jabla and Marciano Mangao), who were themselves implicated albeit in a lesser or subordinate role, could be regarded as credible and trustworthy.
Whether the potential complicity of these witnesses undermined their reliability as sources of evidence against the accused.

Whether the accused, as part of a conspiracy motivated by superstitious beliefs, should be held jointly and severally liable for all three murders committed successively under a common plan.
How the doctrine of conspiracy should influence the assignment of responsibility among the co-conspirators.

Whether the aggravating circumstances (premeditation, use of fire, nighttime execution, cruelty, and in-band participation) warranted the imposition of the death penalty for all three murders.
Whether the mitigating circumstance of “lack of instruction” could offset the imposed aggravating factors, thereby justifying a sentence lower than the death penalty.
How to reconcile the imposition of different penalties for the separate murders while maintaining conformity to statutory limits on cumulative penalty duration.