G.R. No. 45053 - People vs. Piring

At midnight on October 9, 1935, an assailant, whose face was covered by a handkerchief, broke into the house in Maunani, barrio of Ungut, Porac, Pampanga.
The attacker killed the spouses Leonardo (or Leon) Nacpil and Marcelina Mercado while they were asleep, and seriously wounded their 13-year-old son, Jose Nacpil.
After the attack, the perpetrator(s) set the house on fire, and it was later found burned and charred.

Based on initial investigations, Ciriaco Piring, Leoncio Piring, Felix Capili, and Flaviano Capili were identified as the main suspects.
They were charged with double murder and serious physical injuries in separate cases; the double murder charge included aggravating circumstances such as the crime committed in an uninhabited place, with disguise, in a dwelling, at nighttime, with cruelty, and with the aid of armed persons.
Separate trials were conducted: one trial for Felix Capili and Flaviano Capili, and another for Ciriaco Piring and Leoncio Piring.

Except for Ciriaco Piring, the other accused were acquitted due to lack of evidence.
Ciriaco Piring was convicted in the Court of First Instance of Pampanga and sentenced to reclusion perpetua, taking into account:

Mitigating circumstance: his lack of instruction.
Aggravating circumstances: disguise, dwelling, cruelty, and the qualifying circumstance of treachery.

Testimony of the minor, Jose Nacpil, who identified the assailant by voice and clothing.
Exhibit D-1-A: the confession made by Ciriaco Piring before the justice of the peace, in which he stated that he accompanied his uncle, Felix Capili, and others to commit the crime.

He was awoken by the cries of his father and saw a man with a covered face attacking his parents with a bolo.
The assailant's voice and clothes were identical to those of Ciriaco Piring, who was later arrested.
The assailant uttered the words “there is the boy” when speaking to him.

He initially refused to join the plot but eventually complied after his uncle Felix Capili threatened to kill him.
He admitted that he did not personally go up to the house, claiming that only Felix Capili entered the residence to commit the murders and set the fire.

The testimony of Jose Nacpil and evidence from the attire and voice identification were pivotal in contradicting the appellant’s version and proving his direct participation in the crime.

Whether the trial court erred in giving credence to the testimony of the minor, Jose Nacpil, despite the defense’s contention that its miraculous elements rendered it improbable.

Whether the admission of Exhibit D-1-A (the confession made before the justice of the peace) was proper.
Whether the trial court erred in considering the confession in its entirety despite parts of it that the appellant claimed were obtained under threat or were self-incriminatory.

Whether the aggravating circumstances (disguise, dwelling, and treachery) were correctly imputed to the appellant.
Whether the mitigating circumstance of lack of instruction should have more significantly reduced his liability.

Whether sentencing the appellant to reclusion perpetua for each murder (of Leonardo Nacpil and Marcelina Mercado), along with the indemnity to the heirs, was just considering the evidence and circumstances.
How the non-unanimous decision regarding the imposition of the death penalty influenced the final sentence.