Title
People vs. Pacada, Jr.
Case
G.R. No. L-44444-45
Decision Date
Jul 7, 1986
Two brothers, Gregorio and Avelino Pacada, attacked Alfonsa Patnon and her son Romeo in their home, killing Romeo and injuring Alfonsa. Convicted of Murder and Frustrated Murder, their death penalty was reduced to reclusion perpetua by the Supreme Court.

Case Digest (G.R. No. L-44444-45)
Expanded Legal Reasoning Model

Facts:

  • Incident Overview
    • The crime occurred on the evening of September 9, 1974, in Oring, Sta. Maria, Mansalay, Oriental Mindoro.
    • The victim, Alfonsa Patnon, was asleep with family members when she was awakened by the barking of dogs and saw two persons running toward their kitchen.
  • The Assault on Victims
    • Alfonsa Patnon, after lighting a lamp and moving to verify the identities of the persons outside, was suddenly attacked with bolos by two individuals later identified as appellants Avelino Pacada and Gregorio Pacada, Jr.
    • During the same incident, Romeo Patnon, Alfonsa's son, who came out to assist her, was also hacked by the assailants and later died in the hospital.
    • Ofelia Dris Patnon, Romeo’s wife, witnessed the assault, jumped out of the window in a bid to call for help, and reported the incident to her brother-in-law, Nathaniel Patnon.
  • Witness and Evidence Details
    • Testimonies were provided by:
      • Alfonsa Patnon – who identified the assailants in her illuminated sala and detailed the attack.
      • Ofelia Dris – who recognized the attackers during her terrified escape.
      • Nathaniel Patnon – who corroborated the incident by witnessing part of the assault from a distance and overhearing incriminating remarks.
    • A photograph (Exhibit "B") was taken wherein a victim, Alfonsa, pointed to the accused.
    • Additional details include the autopsy of Romeo Patnon and Alfonsa’s subsequent hospitalization for two months, with incurred expenses amounting to P1,700.00.
  • Background and Motive
    • It was revealed that prior to the incident, Alfonsa Patnon had instituted a land case against Cesario Maur, an uncle of the appellants, concerning a disputed parcel of 22 hectares which had been in possession of Alfonsa’s family since 1952.
    • The Pacada family had taken possession of the land and Cesario Maur erected a house thereon, thereby creating animosity.
    • The dispute over land ownership and previous altercations, such as Alfonsa preventing the cutting of bananas, provided a contextual motive for the attack.
  • Alibi and Defense Testimonies
    • Avelino Pacada testified that he was at home praying with his family and a visitor during the time of the incident—with corroboration from Violeta Gramo.
    • Gregorio Pacada, Jr. stated that he was at home with his family and did not leave the premises until the following morning when he was later fetched along with his brother and taken for identification at the Barrio Captain’s house.
    • The defense contended both alibi and denial of involvement, arguing mistakes in witness identification.
  • Trial Court Proceedings and Judgment
    • In the joint decision of Criminal Cases No. P-639 for Murder and No. P-640 for Frustrated Murder:
      • Gregorio Pacada, Sr. and Cesario Maur were acquitted.
      • Gregorio Pacada, Jr. and Avelino Pacada were convicted of both crimes.
    • The convicted appellants were sentenced to death for murder and imposed indeterminate prison terms for frustrated murder.
    • The Trial Court based its judgment on the testimonies of prosecution witnesses who had known the accused for several years and on corroborative evidence, such as the aforementioned photograph and witness observations.

Issues:

  • Identification of the Accused
    • Whether the Trial Court erred in relying on the prosecution witnesses’ identification of the appellants.
    • Whether the witnesses, having long-standing relations with the accused, could have been mistaken in their identification.
  • Defense of Alibi
    • Whether the Trial Court improperly disregarded the alibi defense presented by the appellants, notably that they were at home during the time of the crime.
    • Whether proximity of their homes to the crime scene negated the alibi claim.
  • Guilt Beyond Reasonable Doubt
    • Whether it was erroneous for the Trial Court to find the appellants guilty beyond reasonable doubt for both murder and frustrated murder.
    • Whether the evidence was sufficient to establish the direct participation and the presence of aggravating circumstances such as treachery, nocturnity, and dwelling.
  • Imposition of the Death Penalty
    • Whether the Trial Court erred in sentencing the appellants to the supreme penalty of death for the crime of murder.
    • Consideration of whether mitigating or aggravating circumstances were properly assessed in imposing capital punishment.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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