Case Digest (G.R. No. 95259)
Facts:
On February 8, 1990, the Regional Trial Court, Branch 21, Cagayan de Oro, presided over by Judge Celso P. Lagro, rendered a judgment in Criminal Case No. 89-051, convicting Bernardo Peran, Felix Piquero, and Junior Narido of murder. The incident occurred on May 10, 1988, at approximately 7:00 AM, when the deceased, Jose Namoc, and accused-appellant Bernardo Peran had an altercation over a puppy. Following the argument, Jose asked his companion, Roberto Cawasan, to go ahead while he fed the chickens. Roberto, however, remained nearby and witnessed the three accused-appellants approach Jose's house. He observed them forcibly lead Jose to a creek, where Bernardo struck him with a piece of wood, followed by Junior hitting him with a stone, and Felix delivering a blow to his mouth. After the attack, Jose's body was hidden, and it took 47 days for his remains to be discovered near the Calabasa Waterfalls. Roberto, initially silent due to fear, eventually reported the incide...
Case Digest (G.R. No. 95259)
Facts:
- 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.
- 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.
- 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.
- 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.
- Confession and Arrest: Bernardo Peran confessed to the crime, implicating Junior Narido and Felix Piquero. This led to their arrest.
- 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:
- 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.
- 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.
- Abuse of Superior Strength: While present, it cannot qualify the crime as murder unless explicitly alleged in the information.
- Penalty: The penalty must correspond to the crime proven. Since the crime was homicide, not murder, the penalty was reduced accordingly.