G.R. No. 101451 - People vs. Regalario y Villagracia

The case involves the killing of Menardo Garcia on September 18, 1986, in Lucena City, Quezon Province.
Six accused—Alex Regalario, Carlos Pabillar, Jose Quiniquito, Rolando de Chavez, Augurio Villagracia, Jr., and Alberto Desembrana—were charged with murder under Article 248 of the Revised Penal Code.
The information alleged that the accused, acting in concert and with evident premeditation, conspired to attack, assault, and stab the victim, thereby causing his death.

At about 9:00 o’clock in the evening, Menardo Garcia was walking home from Quezon National High School accompanied by Glenda Osabal and Romano Padillo.
As the trio neared the school gate near the Division Office, the six accused joined them.

Accused Carlos Pabillar questioned Garcia regarding the location of a “balisong” (a type of knife).
After Garcia explained that the balisong was no longer in his possession, Pabillar boxed him and urged his companions with the command “tirahin na iyan” (attack him).
Menardo Garcia attempted to flee, but the group chased and overtook him about 50 meters from the school gate.
During the pursuit, the accused engaged in a coordinated assault by boxing Garcia, with Alex Regalario additionally stabbing him.
Witnesses, including Romano Padillo and Glenda Osabal, observed the attack, and the victim’s subsequent collapse and inability to stand led to his eventual death, attributed to massive internal hemorrhage resulting from the stab wound.

Apprehensions were made at various times—with some accused caught immediately after the incident and others, such as Desembrana, apprehended later for different offenses.
During arraignment on October 28, 1986, all accused, except Desembrana, initially pleaded not guilty.

Before the prosecution rested, appellants Regalario and Pabillar changed their pleas to guilty upon re-arraignment, with the court ensuring they were assisted by counsel and understood the nature of the charge.
Desembrana maintained a not guilty plea despite his later involvement.

The trial court found all accused guilty beyond reasonable doubt.
The court noted the aggravating circumstance of abuse of superior strength and the existence of conspiracy among the accused.
Sentences ranged from reclusion perpetua for those not invoking mitigating circumstances to reduced penalties for those who successfully claimed minority, with additional orders for payment of death indemnity and expenses in favor of the victim’s heirs.

Following the promulgation of the judgment on January 17, 1991, a motion for reconsideration was filed on January 31, 1991 and denied on February 22, 1991.
A notice of appeal was subsequently filed on March 4, 1991; however, this filing was challenged as being out of time according to the reglementary period provided in Section 6, Rule 122 of the Rules of Court.
Appellants raised several issues on appeal including:

The proper computation of the appeal period and whether the appeal was timely or time-barred.
The propriety of accepting the change of plea to guilty by Regalario and Pabillar without fully apprising them of the nature and consequences of the charge.
The sufficiency of evidence establishing a common conspiracy among the accused.
The weight given to the testimonies of prosecution witnesses versus those offered by the defense.
The credibility and admissibility of evidence concerning the minority (age) of some accused as a mitigating circumstance.

The prosecution relied heavily on the consistent and detailed testimonies of eyewitnesses Glenda Osabal and Romano Padillo, who identified the accused and narrated the sequence of the attack.
The autopsy report provided medical findings in support of the claim of a fatal stab wound with internal injuries leading to the victim’s death.
The defense introduced an alternative version of the events, contending that the encounter began over a dispute regarding a balisong, and argued that the acts of boxing and stabbing were independent rather than coordinated as part of a conspiracy.
Evidence regarding the age of the accused, through birth and baptismal certificates, was presented to establish the mitigating circumstance of minority for some appellants.

Whether the notice of appeal was filed within the reglementary period set by Section 6, Rule 122 of the Rules of Court.
The proper computation of the appeal period, especially considering the interruption caused by the filing and denial of a motion for reconsideration.

Whether the acceptance of the change of plea to guilty by Regalario and Pabillar was proper, given that the accused were assisted by counsel during re-arraignment.
Whether their subsequent arguments regarding the pleading and its consequences could be raised for the first time on appeal.

Whether the acts of the accused, including the coordinated boxing and stabbing of the victim, were sufficient to establish a common design or conspiracy.
The weight that should be given to the circumstantial evidence and the eyewitness testimonies in proving that the accused acted in concert.

Whether the lower court properly appreciated and weighed the testimonies of the prosecution witnesses over the conflicting defense narratives.
The implications of any discrepancies or lack of corroborative evidence concerning the defense testimonies.

Whether the evidence presented on the ages of the accused was sufficient to establish the mitigating circumstance of minority.
The proper application of the doctrine favoring the interpretation of mitigating circumstances in favor of the accused, particularly regarding their age.

Whether the computation and imposition of the death indemnity, as well as funeral and other incidental expenses, were in accordance with prevailing law and case precedents.
Whether the increased indemnity award and the adjusted penalties for those who could successfully claim minority were properly justified.