G.R. No. 69986 - People vs. Pacris

A criminal complaint was filed by the Integrated National Police of Sanchez Mira, Cagayan accusing several persons of murder.
The incident involved accused Valeriano Pacris, Nestor Pacris, Benito Pacris, Mauricio Galzote, and Froilan Pacris (the latter later acquitted).
A warrant for arrest was issued following the allegation that, armed with a sharp pointed instrument, pieces of wood, and bamboo, the accused conspired in killing Rogelio Lim.
Bail was initially denied due to the gravity of the charge; however, a petition for bail resulted in the fixing of a bond at P40,000.00 for each accused and their subsequent provisional release.

The crime took place on April 30, 1980, between 5:00 and 6:00 in the morning at Masisit, Sanchez Mira, Cagayan.
Rogelio Lim, accompanied by four friends while taking breakfast near an "apar" (a small shelter or shade), encountered a group of men involved in catching bangus fry.
Upon discovering that the fishing activity was allegedly carried out under the instruction of Valeriano Pacris, Lim engaged in conversation with the men.
Without warning, Nestor and Valeriano Pacris approached from the rear while Lim was facing southwest, initiating the attack.
Nestor Pacris used a wooden paddle to club Lim, and as Lim turned to confront the attack, Valeriano Pacris knelt beside him and stabbed him with a pointed iron tool.
Following the initial assault, Benito Pacris, Mauricio Galzote, and other unidentified individuals joined in the clubbing, resulting in a concerted and merciless assault that left Lim with twenty-one wounds — eight of which were fatal as confirmed by the post mortem examination.

Testimonies from eyewitnesses (notably Ernesto Monje, Samson Adolfo, Tomas Natividad, and others) who described the sequence and manner of the assault.
Autopsy reports by Dr. Ruben Angobung that documented multiple wounds, fractures, hemorrhages, and concussions sustained by the victim.

The defense, while presenting an alibi and a claim of self-defense (particularly by Valeriano Pacris), failed to produce evidence of any unlawful, unprovoked aggression by the victim.
The trial court found that despite the absence of direct evidence of a prior agreement to kill, the concerted action of the accused demonstrated a clear conspiracy to commit murder.
The prosecution’s account, supported by the physical evidence and consistent eyewitness testimony, led the trial court to convict four of the accused for murder.

The trial court sentenced Valeriano, Nestor, Benito Pacris, and Mauricio Galzote to death, while acquitting Froilan Pacris for insufficiency of evidence.
With the death penalty rendered non-enforceable by the 1987 Constitution, the death sentences were automatically commuted to reclusion perpetua for the applicable accused.
Upon review, modifications were made:

Valeriano Pacris and Mauricio Galzote were credited with the mitigating circumstance of voluntary surrender and sentenced under the Indeterminate Sentence Law (imprisonment ranging from 17 years and 4 months to 20 years).
Nestor Pacris and Benito Pacris, lacking such mitigating circumstances, were sentenced to reclusion perpetua.

All accused were ordered to indemnify the heirs of Rogelio Lim for moral damages, increased from P12,000.00 to P50,000.00.

Whether the trial court correctly identified and applied the qualifying aggravating circumstances (evident premeditation, treachery, cruelty, and taking advantage of superior strength) to qualify the crime as murder.
The appropriateness of considering the aggravating circumstance of taking advantage of superior strength as distinct from treachery.

Whether sufficient evidence existed to infer conspiracy among the accused, despite no direct evidence of a prior agreement.
Whether the concerted and simultaneous manner of the attack justified the finding of conspiracy.

Whether the court gave appropriate credence to the consistent and corroborative testimonies of prosecution witnesses, notably Ernesto Monje and Tomas Natividad.
Whether the accumulated evidence was sufficient to establish the guilt of the accused beyond reasonable doubt.

Whether the self-defense claim by Valeriano Pacris was valid under the circumstances presented.
Whether the mitigating circumstance of voluntary surrender was properly recognized and merited a lesser sentence for the accused who surrendered.