G.R. No. L-30527-28 - People vs. Padernal

On January 30, 1965, Geminiano de Leon, accompanied by his common-law wife Fabiana Rosales and his son Marianito de Leon, visited Barrio Tagbacan Silangan in Catanauan, Quezon.
Geminiano de Leon owned a parcel of land in the barrio which he cultivated as kaingin, and he was expecting his share of the palay harvest from Pio Ricohermoso, who cultivated the land.
During their morning conversation, Geminiano inquired about his share, and Ricohermoso initially promised palay when Geminiano would later visit his house.

In the afternoon, around two o’clock, Geminiano returned to Ricohermoso’s place as agreed.
Geminiano sat beside Fabiana while his son Marianito stood behind him, with a .22 caliber rifle slung on his shoulder.
Ricohermoso, now displaying a hostile and defiant tone, stated that he would not give any palay despite earlier assurances.
In response, Geminiano questioned Ricohermoso’s earlier invitation to his house, but the situation rapidly escalated.

Without warning, Ricohermoso unsheathed his bolo and approached Geminiano from the left, while Severo Padernal, positioned near the eaves and identified as Ricohermoso’s father-in-law, advanced with an axe from the right.
Amid Geminiano’s pleas—raising his hands and calling out to Severo Padernal as “Mamay (Grandpa)”—the attackers did not relent.
Ricohermoso inflicted a fatal wound by stabbing Geminiano on the neck with his bolo, and Severo Padernal hacked Geminiano’s back with an axe.
Compassingly, at the same time, appellant Juan Padernal embraced Marianito de Leon from behind, effectively immobilizing him; this action forestalled any attempt by the latter to use his rifle, thereby ensuring no external interference during the assault.

The forensic report by Doctor Isabela A. Matundan detailed multiple wounds on Geminiano de Leon:

A deep incised wound on the lateral aspect of the neck, cutting through the carotid artery and the jugular vein, which was deemed instantly fatal.
Additional incised wounds on the lumbar region of the back and on the dorsal waist, with the back wound having the potential to be fatal if the kidney had been penetrated.

Marianito de Leon sustained abrasions and a lacerated wound on the left foot, injuries that were not life-threatening.

The prosecution’s evidence unequivocally established a premeditated and concerted plan by Ricohermoso, Severo Padernal, and Juan Padernal to assassinate Geminiano de Leon.
Appellants’ version attempted to shift responsibility solely on Ricohermoso, contending that Geminiano’s own actions and unsheathing of a bolo initiated the violence.
Notably, Severo Padernal, in his appeal, eventually withdrew his contention and tacitly accepted the prosecution’s narrative, thereby weakening the appellants’ defense.
The evidence underscored that:

Ricohermoso had changed his stance between the morning and afternoon meetings.
The coordinated assault—with Ricohermoso and Severo Padernal executing predetermined roles—was reinforced by Juan Padernal’s deliberate act of subduing Marianito de Leon.

The Circuit Criminal Court at Lucena City convicted Severo Padernal and Juan Padernal of murder (with a sentence of reclusion perpetua) and imposed a joint payment for damages to the heirs of Geminiano de Leon.
They were also convicted of lesiones leves in a separate count regarding the injuries sustained by Marianito de Leon.
The sole issue on appeal—pertaining specifically to Juan Padernal—was whether he had actively conspired with Ricohermoso and Severo Padernal in the assassination of Geminiano de Leon.

Whether appellant Juan Padernal conspired with Ricohermoso and Severo Padernal to kill Geminiano de Leon.

Did his actions—specifically, the deliberate immobilization of Marianito de Leon—constitute active participation in a conspiracy to commit murder?
Is the invocation of the justifying circumstance under Article 11 (regarding the avoidance of a greater evil) valid for his actions?

Whether the collective conduct of the assailants displayed a concerted effort that fulfills the legal definition of conspiracy leading to murder.