Case Digest (G.R. No. 85823)
Facts:
The case in question, People of the Philippines vs. Alex Padrones and Joseph Biare @ "Jojo" Biare, pertains to the murder of Lorenzo Sison, Jr. The decision was rendered by the Second Division of the Supreme Court on September 13, 1990, as G.R. No. 85823. On August 3, 1986, Lorenzo Sison celebrated his birthday at the MGR Family Disco and Restaurant located in Surallah, South Cotabato, surrounded by about fourteen relatives, including his nephews and nieces. On the night of the incident, two accused, Padrones and Biare, arrived at the establishment at different times, with Biare coming around 12:30 a.m. and Padrones appearing approximately ten minutes later. Initially, the two greeted each other and exchanged pleasantries before separating to sit at different tables.During the celebration, an altercation ensued between Padrones and Sison when the former was allegedly confronted by Lorenzo, who reportedly stated, “Are you not afraid of the Sisons?” Things escalated, leading to
Case Digest (G.R. No. 85823)
Facts:
- Incident Background
- On August 3, 1986, Lorenzo Sison was celebrating his birthday at the MGR Family Disco and Restaurant in Surallah, South Cotabato with about fourteen nephews and nieces.
- The festive atmosphere was later disrupted by a violent altercation that resulted in serious injuries and ultimately the victim’s death.
- Arrival and Initial Interaction of the Accused
- The two accused, Alex Padrones and Joseph “Jojo” Biare, arrived at the scene separately on the early hours of August 4, 1986.
- Biare arrived at approximately 12:30 to 1:00 in the morning.
- Padrones arrived nearly ten minutes after Biare.
- Although they appeared as old acquaintances—having not seen each other for six months—they initially exchanged pleasantries and shook hands before going their separate ways.
- The Altercation and Physical Confrontation
- The victim, while engaging with Padrones, challenged him by saying, “Are you not afraid of the Sisons?”—referring to a family reputed for its local and national influence.
- A series of events ensued that involved:
- Padrones alleging that he saw a knife glinting in the disco lights as the victim lunged at him with a knife.
- A physical struggle where Padrones defended himself, during which he sustained injuries (a cut on the left wrist and a wound on his left cheek).
- Antonio Llaneta, an alleged eyewitness who was with the victim, intervened by striking Padrones on his left cheek.
- Amid the melee, the situation descended into pandemonium with multiple individuals brawling and bottles flying, leaving Padrones bloodied and crawling on the disco floor.
- Post-Altercation Developments
- According to Biare’s testimony, after the brawl:
- Padrones was seen with hands raised in a gesture of surrender, pleading for help with cries of “Please help me, have mercy on me.”
- Biare offered to assist Padrones, claiming he would take him home on his motorcycle, all the while denying any direct involvement in stabbing the victim.
- Medical examinations later revealed:
- Padrones sustained a superficial incised wound on the left forearm.
- The victim, Lorenzo Sison, suffered two distinct stab wounds—one on the right chest and another on the left side—which penetrated vital cavities and organs, as testified by Dr. Jose Velasquez.
- A handwritten statement by the injured victim, executed on August 13, 1986, allegedly implicated Padrones and Biare in his stabbing, although its validity as a dying declaration was later questioned.
- Investigative and Prosecution Proceedings
- Frustrated homicide charges were initially filed against Padrones on August 6, 1986; subsequently, on November 4, 1986, an amended information charged both accused with murder, qualified by treachery and evident premeditation.
- Evidence presented at trial included:
- Testimonies from eyewitnesses such as Antonio Llaneta, who claimed to have seen Padrones stab the victim, and other witnesses including Emily Bautista and Federico Sison who corroborated the act by Padrones.
- Forensic evidence and medical expert testimony regarding the nature and extent of injuries on both the victim and Padrones.
- The trial court convicted both accused on the basis of the prosecution’s evidence, finding them guilty beyond reasonable doubt for the crime of murder—in part based on the perceived conspiracy and the behavior exhibited during the altercation.
Issues:
- Credibility and Reliability of the Evidence
- Whether Antonio Llaneta’s testimony, particularly his identification and description of the events, was sufficiently reliable and credible.
- The validity and admissibility of the alleged ante-mortem (or dying) declaration by the victim, especially given the circumstances under which it was executed.
- Establishment of Conspiracy and Premeditation
- Whether the fact that the accused encountered each other “by chance” at MGR can be equated with a pre-arranged agreement to commit murder.
- Whether the subsequent actions by Biare, such as his assistance to Padrones after the altercation, constitute evidence of a conspiratorial plan rather than isolated acts of friendship or self-preservation.
- Self-Defense and the Sequence of Events
- Whether Padrones’ account of self-defense is consistent with the physical injuries sustained and the overall sequence of the altercation.
- Whether the chaotic conditions during the birthday celebration provide a reasonable context for the altercation, thereby affecting the interpretation of self-defense claims.
- Determination of Appropriate Criminal Liability
- Whether the evidence supports a conviction for murder with aggravating circumstances (treachery and premeditation) or whether it warrants a conviction for the lesser offense of homicide.
- The extent to which the joint actions of the accused (if any) amount to shared criminal liability or whether one should be held responsible while the other is exonerated.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)