Facts:

The case involves the People of the Philippines as the plaintiff-appellee against Renato Moral, Abraham Antonio, and Leopoldo Pedrigosa as defendants-appellants, with the decision rendered on October 12, 1984, by the Supreme Court of the Philippines. The events leading to the case occurred on May 3, 1969, in Makati, Rizal. The defendants were charged with murder for the fatal assault of Teodoro Casa. The charge alleged that Renato Moral, in conspiracy with his brother Alexander Moral—who remained at large—attacked Casa with a knife, while the accomplices, Abraham Antonio and Leopoldo Pedrigosa, assisted by throwing stones at the victim. Teodoro Casa, who lived in the same boarding house as the accused, confronted them for their disorderly conduct during a drinking session. The results of the encounter were disastrous; Casa was stabbed multiple times and sustained fatal injuries. Various witnesses corroborated the prosecution's account, testifying to the sequence of events an

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Facts:

Background of the Case

• The criminal case involved the People of the Philippines charging Renato Moral as principal and Leopoldo Pedrigosa and Abraham Antonio as accomplices for the murder of Teodoro Casa.
• The crime occurred on May 3, 1969, in Makati, Rizal, during an incident at night, with surrounding circumstances that included premeditation, treachery, and the use of knives and blunt instruments.

Narrative of the Incident

• Prior to the murder, the accused—Renato Moral, Leopoldo Pedrigosa, Abraham Antonio, and a co-accused Alexander Moral (who was not apprehended at the time)—attended a drinking session at a rented house.
• The group became intoxicated, singing, shouting, and engaging in rowdy behavior.
• During the drinking session, one of the gang uttered an inflammatory statement challenging anyone to speak against them.
• The disturbance caused discomfort among the residents, particularly Teodoro Casa (and his sister Luz Casa), who resided above the rented house.
• Teodoro Casa requested for the noise to cease and approached the landlord’s residence.
• Despite attempts by both Teodoro Casa and the landlord to calm the situation, the accused continued their disruptive behavior.
• The escalation led to the critical moment when, around 9:30 p.m., while Teodoro Casa was returning from answering a call of nature:
• Luz Casa heard Renato Moral proclaim “Yayariin natin si Teodoro Casa” (Let’s get Teodoro Casa).
• As Teodoro Casa exited the toilet, he was confronted by Renato Moral armed with a knife.
• The assault ensued as Teodoro Casa was stabbed; when he attempted to flee, he encountered further violence from Alexander Moral alongside accomplices Pedrigosa and Abraham Antonio.
• Testimonies from Luz Casa and other witnesses recount that both stabbing and blunt trauma by stones and bottles were inflicted, ultimately resulting in Teodoro Casa’s death.

Testimonies and Evidence

• Prosecution witnesses, including Luz Casa, Andres Guinanao, Ceferino Cerbo, and police officers, provided detailed accounts of the events.
• These testimonies described the sequence of attacks, the identification of the assailants, and the involvement of the accused in throwing stones and physically assaulting the victim.
• Medical evidence from the necropsy report confirmed fatal wounds consistent with the witness accounts.
• The prosecution also presented documentary exhibits (e.g., Exhibit A and Exhibit C) and investigative reports supporting the identification and participation of the accused.

Defendant’s Versions and Defenses

• Renato Moral’s account:
• Claimed he was working as a mason in Quezon City and later visited the house of a friend before proceeding to the house of Alexander Moral.
• Stated that during a routine washing of rice, he was suddenly attacked by Teodoro Casa along with another accomplice, which led to him being assaulted and fainting.
• Abraham Antonio’s defense:
• Asserted that he acted in defense of a stranger after witnessing Renato Moral being attacked by Teodoro Casa and Ceferino Cerbo, leading him to throw a stone.
• Leopoldo Pedrigosa’s alibi:
• Claimed he was at the house of his friend Rodolfo Reodique, located approximately 20 meters from the incident scene, and only learned of the attack when Renato Moral and Abraham Antonio later returned.

Trial Court Decision and Subsequent Developments

• The trial court rejected the defenses and established the credibility of the prosecution witnesses despite noting minor discrepancies.
• All accused were initially found guilty and sentenced to death, along with an order to indemnify the heirs of Teodoro Casa.
• Renato Moral’s subsequent death in prison led to the dismissal of the case against him, while the remaining accused sought review of their sentences.
• The case ultimately came under mandatory review for the appropriateness of the death penalty imposed on individuals found guilty as accomplices.

Issue:

Credibility and Reliability of Prosecution Witnesses

• Whether the minor inconsistencies in the testimonies of the prosecution witnesses are sufficient to render the overall accounts unreliable.
• The effect of the illumination at the scene and the recall of the witnesses in identifying the assailants.

Validity of the Defenses Raised by the Accused

• The credibility of Renato Moral’s alibi and his version that he was engaged in routine activities.
• The plausibility of Abraham Antonio’s defense of stranger amid the conclusive evidence of unprovoked aggression.
• The strength of Leopoldo Pedrigosa’s alibi, considering his physical proximity to the crime scene.

Appropriateness of the Death Penalty Imposed

• Whether imposing the death penalty on accomplices is consistent with Article 52 of the Revised Penal Code.
• If the cumulative aggravating circumstances warrant the capital punishment or if a lesser penalty is appropriate.

Evaluation of Aggravating and Mitigating Circumstances

• The significance of alleged premeditation, nocturnity, abuse of superior strength, and intoxication in aggravating the crime.
• Whether the evidence sufficiently supports the classification of these factors as aggravating, or if intoxication should be considered mitigating.

Appropiateness of Applying the Penalty Next Lower in Degree for Accomplices

• How Article 52 of the Revised Penal Code should guide the sentencing of accomplices in a felony murder case.
• The rationale for adjusting the penalty from the death sentence to an indeterminate sentence of imprisonment.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)