Case Digest (G.R. No. L-38831)
Facts:
The People of the Philippines v. Marvin Millora and Justo Millora, G.R. No. L-38831, December 27, 1982, Supreme Court Second Division, Aquino, J., writing for the Court.The prosecution charged Marvin Millora and his younger brother Justo “Tito” Millora, together with Feliciano “Tony” Munoz, with the murder of Arnulfo Benitez on the night of April 27, 1972 in San Carlos City, Pangasinan. According to eyewitnesses, a red jeep carrying the three stopped near Benitez and his companions; the three alighted armed (Marvin with a .45 pistol, Tito with an armalite, Tony with a carbine). Benitez fled into Virgen Milagrosa Hospital but later returned to the street, where he was intercepted, shot, stabbed and later dumped; his body was found the next day in a ricefield in Barrio Duyong, Calasiao. Autopsy showed multiple gunshot wounds, a stab wound and incised wounds.
Local police made no thorough investigation allegedly due to fear of the assailants; the case was later investigated by the Constabulary. Tony Munoz was arrested about four months after the killing and executed a confession implicating the Millora brothers. The city fiscal filed an information on February 26, 1973 charging Munoz and the Millora brothers with murder qualified by treachery, abuse of superiority and evident premeditation.
At the trial in the Circuit Criminal Court at Dagupan City, the accused pleaded alibi: Marvin claimed to have been playing mahjong at home; Tito claimed to have been serving at the mahjong game. Tony testified he was in Caloocan. The trial court rejected the alibis, found that prosecution eyewitnesses (Isabelo Pagdanganan, Felipe Canilang and Councilor Manuel Magali) positively identified the Millora brothers and Munoz as the killers, and convicted Marvin and Tony of murder qualified by treachery, sentencing them to “life imprisonment” and ordering solidary indemnity of P12,000 to the heirs. The trial court found Tito, who was 14 at the time of the crime, acted with discernment but suspended his sentence and ordered commitment to a rehabilitation center.
To...(Pro-only)
Issues:
- Was the identification and proof of guilt of the appellants sufficient to sustain their convictions beyond reasonable doubt despite delayed statements, minor inconsistencies, and asserted alibis?
- Was the killing properly qualified as murder by treachery, abuse of superiority, and evident premeditation, and was the penalty correctly imposed (including the trial court's designation of “life imprisonment”)?
- Given that Tito was fourteen years old at the time of the crime, was he entitled to a suspended sentence or other mitig...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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