Facts:

The case involves appellants Julito Mindac, Lino Trinidad, and Carlito Laguras, who were charged with murder in the Regional Trial Court of Dumaguete City, Branch XXX. The incident occurred on June 19, 1983, at approximately 7:30 PM along the National Highway in Zamboanguita, Negros Oriental. The information alleged that the accused conspired to kill Cirilo "Glenn Boy" Bolisig, inflicting fatal wounds using a hunting knife, an empty long neck bottle, and a belt. The victim sustained multiple injuries, including a stab wound that penetrated the fifth intercostal space, leading to his immediate death.

Upon arraignment, the accused pleaded not guilty. During the trial, Mindac admitted to the killing but claimed self-defense. The prosecution presented evidence, including testimonies from witnesses who observed the attack. The trial court found the accused guilty of murder, citing the aggravating circumstance of superior strength, and sentenced them to reclusion perpet...

Facts:

1. Incident Details: On June 19, 1983, at around 7:30 PM, Cirilo "Glenn Boy" Bolisig was walking along the National Highway in Zamboanguita, Negros Oriental, when he was attacked by Julito Mindac, Lino Trinidad, and Carlito Laguras. The accused blocked his path, assaulted him with a belt, an empty bottle, and a hunting knife, resulting in fatal injuries.
2. Victim's Injuries: The victim sustained abrasions on the nose and chin and a fatal stab wound below the left nipple, which caused his immediate death.
3. Prosecution's Case: Witnesses testified that the accused conspired to attack the victim. Pastor Canete, a prosecution witness, stated that the accused blocked the victim’s path, assaulted him, and Julito Mindac delivered the fatal stab.
4. Defense's Case: Julito Mindac admitted to killing the victim but claimed self-defense, alleging that the victim attacked him first with a stone and a knife. The defense presented conflicting testimonies about the sequence of events.
5. Trial Court's Findings: The trial court found the accused guilty of murder, citing conspiracy and abuse of superior strength. The court rejected the defense of self-defense and the recantation of prosecution witnesses.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Self-Defense: For self-defense to be valid, there must be clear evidence of unlawful aggression, reasonable necessity of the means employed, and lack of sufficient provocation. The defense failed to prove these elements, particularly unlawful aggression.
2. Conspiracy: Conspiracy can be inferred from the coordinated actions of the accused, even without direct evidence. The accused’s concerted attack on the victim demonstrated a common purpose to kill.
3. Abuse of Superior Strength: This qualifying circumstance applies when the attackers use their combined strength to overpower the victim, ensuring the crime’s success.
4. Retraction of Testimony: Retractions are viewed with disfavor, as they undermine the integrity of judicial proceedings. Prior testimonies given under oath carry more weight than subsequent recantations.
5. Voluntary Surrender: To qualify as a mitigating circumstance, voluntary surrender must involve a spontaneous acknowledgment of guilt and a desire to submit to the authorities. Mere notification of the incident does not suffice.
6. Alibi: Alibi is a weak defense and must be supported by clear and convincing evidence. In this case, the testimonies of multiple witnesses placed Laguras at the scene of the crime.