Title
People vs. Peran
Case
G.R. No. 95259
Decision Date
Oct 26, 1992
A 1988 altercation over a puppy led to Jose Namoc's killing by Bernardo Peran, Junior Narido, and Felix Piquero. The Supreme Court ruled it as homicide, not murder, due to insufficient proof of treachery, imposing a reduced penalty.
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Case Digest (G.R. No. 95259)

Facts:

  1. Incident Overview: On May 10, 1988, at around 7:00 AM, an altercation occurred between Jose Namoc (the victim) and Bernardo Peran (one of the accused) over the ownership of a puppy. Bernardo left the scene visibly angry.
  2. Witness Testimony: Roberto Cawasan, a 16-year-old eyewitness, testified that after the altercation, he saw Bernardo Peran, Junior Narido, and Felix Piquero approach Jose Namoc's house. They forcibly took Jose to a nearby creek.
  3. The Killing: At the creek, Bernardo struck Jose on the forehead with a piece of wood, causing him to fall. Junior Narido then hit Jose with a stone, and Felix Piquero delivered a final blow with his fist. Roberto fled the scene out of fear.
  4. Discovery of the Body: After 47 days, the victim's decomposing body was found near Calabasa Waterfalls. The body showed signs of a broken forehead and missing teeth.
  5. Confession and Arrest: Bernardo Peran confessed to the crime, implicating Junior Narido and Felix Piquero. This led to their arrest.
  6. Defense Version: Bernardo claimed that Jose died accidentally after falling from a waterfall while they were catching frogs. He admitted to hiding the body out of fear of being blamed.

Issue:

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Ruling:

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Ratio:

  1. Credibility of Witnesses: The trial court's findings on witness credibility are generally upheld unless there are substantial reasons to overturn them. Fear of reprisal is a valid excuse for delayed reporting.
  2. Qualifying Circumstances: For a killing to be classified as murder, qualifying circumstances such as treachery must be clearly proven. Conspiracy alone does not qualify a crime as murder.
  3. Abuse of Superior Strength: While present, it cannot qualify the crime as murder unless explicitly alleged in the information.
  4. Penalty: The penalty must correspond to the crime proven. Since the crime was homicide, not murder, the penalty was reduced accordingly.


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