Case Digest (G.R. No. 254875)
Facts:
In G.R. No. 254875 decided on February 13, 2023 under the 1987 Constitution, the Supreme Court reviewed the consolidated prosecutions against Jonie Sabandal Pilen, who, on July 14, 2013 at around 7:00 p.m. in Barangay Cantutang, Padre Burgos, Southern Leyte, allegedly armed himself with a bolo and viciously attacked residents. Three victims—Princess Aclao Jabonero (22 years), Maria R. Felicilda, and one-year-old Leslie Ann Salem Kaindoy—died from stab and hack wounds, while others sustained serious injuries. Pilen was arraigned before the Regional Trial Court (RTC) of Maasin City, Branch 25, charged with three counts of Murder, ten counts of Frustrated Murder, and two counts of Attempted Murder. After being cleared to stand trial following psychiatric evaluation, he pleaded not guilty. The RTC’s August 17, 2018 Decision convicted him of three murders (reclusion perpetua), eight frustrated murders (indeterminate penalties), and two attempted murders, with awards of civil indemni
Case Digest (G.R. No. 254875)
Facts:
- Case Origin
- Accused-appellant Jonie Sabandal Pilen was charged by Informations in 13 consolidated criminal cases in the RTC of Maasin City, Southern Leyte, for:
- Three counts of Murder (Princess Aclao Jabonero, Maria R. Felicilda, one‐year‐old Leslie Ann Salem Kaindoy)
- Ten counts of Frustrated Murder (various victims)
- Two counts of Attempted Murder (Georgia Ina Jabonero, Zenaida V. Aguelo)
- Before arraignment, the RTC ordered a psychiatric evaluation; Pilen was found competent to stand trial.
- Pilen pleaded “not guilty.” Pre‐trial and trial on the merits ensued.
- Incident of July 14, 2013 in Barangay Cantutang
- At about 7:00 p.m., Pilen first stabbed Princess, Georgia, and Love Joy outside the Jabonero residence after a brief exchange.
- He then attacked in succession:
- Genara Chu – stabbed without provocation while washing dishes.
- April Rose Salem – hacked multiple times as she walked home.
- Roger Salem – stabbed when confronted about April Rose.
- Aiza Salem Kaindoy and her 1½-year-old daughter, Leslie Ann – both hacked; Leslie Ann died instantly.
- Maximo L. Palero (and wife) – stabbed Maximo; wife struck by bolo handle.
- Zenaida V. Aguelo – hacked on the back as she tried to enter her house.
- Jolito U. MariAo and Maria R. Felicilda – blocked and stabbed on the road; Maria died.
- Victims were rushed to hospital; Princess, Maria, and Leslie Ann died; others survived due to medical intervention.
- Pilen was arrested; his bolo recovered.
- Trial Evidence
- Prosecution witnesses: all surviving victims, attending physicians (Drs. Abiera, Sibud, Tan, Borres), investigating police officer.
- Medical certificates established nature and severity of wounds; physicians testified fatality risk without timely treatment.
- Defense evidence: Pilen’s lone testimony claiming he was forcibly intoxicated on drugs and lacked recollection.
- Lower Court Decisions
- RTC (Aug. 17, 2018):
- Convicted Pilen of Murder (three counts) by treachery.
- Convicted Pilen of Frustrated Murder (eight counts) and Attempted Murder (two counts).
- Rejected insanity defense.
- CA (July 7, 2020):
- Upheld convictions but downgraded most Murder counts to Homicide due to defective pleadings on treachery/premeditation, except Leslie Ann’s killing.
- Rejected insanity defense and objections to expert testimony.
- Supreme Court Appeal
- Pilen appealed to the Supreme Court urging: insufficiency of Information, insanity defense, failure to prove treachery/premeditation, non-expert status of doctors, and improper staging for one victim.
- OSG and Public Attorney’s Office filed briefs; case submitted for decision.
Issues:
- Whether Pilen waived defects in the Informations and whether the killings qualify as Murder or only Homicide.
- Whether treachery or evident premeditation was proved for victims other than Leslie Ann.
- Proper classification of stages of felony (consummated/frustrated/attempted) for each victim.
- Whether the insanity defense was established.
- Admissibility and weight of expert medical testimony.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)