G.R. No. 76954-55 - People vs. Renejane

The case involves the People of the Philippines versus Beniano Renejane, with five co-accused remaining at large.
The accused was charged in two separate informations for two counts of murder committed on November 1, 1981, at 11:00 p.m. in Barangay Lamesa, Municipality of Balamban, Cebu.
The murders involved two victims: Patrolman Mario de Jesus and Regino Mara-asin, whose deaths were inflicted with extreme cruelty and multiple stabbings.

Prior to the incident, a group led by Renejane, including Ireneo Nick Laborte, Benjamin Purisima, Paulino Laborte, Loreto Bacus, and Rudolfo Ripdos, engaged in a drinking session that involved movement among different houses.
The accused and his cohorts visited several locations:

They had lunch at Reynoso Mara-asin’s parents’ house.
They later proceeded to the house of Artemio Ripdos where beer was consumed.
The group then moved to Beniano Renejane’s house for food and drinks, followed by visits to the houses of Nick Laborte’s mother and finally Paulino Laborte’s house.

An eyewitness, Pablo Sumandig, testified about an argument involving Renejane and Patrolman Mario de Jesus over marijuana.
The conflict escalated resulting in the stabbing and killing of both victims, with Sumandig observing that three persons participated in the attack.

He placed Paulino Laborte as the first to draw his knife and attack.
He identified that Renejane made the subsequent, fatal stabbing of the policeman.
He noted that a third assailant attacked Regino Mara-asin, leaving multiple stab wounds even after death.

Reynoso Mara-asin corroborated the sequence of events by noting the invitation extended by Renejane to partake in food and drinks, and later the movement from one house to another.
Artemio Ripdos confirmed the presence of several witnesses and the movement of the group which helps establish the timeline.

The defense raised Epifania Riponte’s testimony, asserting that Sumandig was not present at Barangay Lamesa on the day of the massacre.
However, her own testimony merely stated that she did not know Sumandig personally and confirmed her own whereabouts, thus not directly refuting Sumandig’s account.

Renejane is alleged to have harbored a personal grudge against Patrolman Mario de Jesus, stemming from an earlier encounter for illegal marijuana possession.
Regino Mara-asin was suspected by the accused of having acted as an informer.
The crimes were compounded by the excessive and deliberate infliction of wounds, aiming to augment the victims’ suffering even after they were already dead.
The intensity of the assault was fueled by the group’s intoxication and a desire for revenge.

The Regional Trial Court of Cebu, Branch VIII, found Beniano Renejane guilty beyond reasonable doubt of Double Murder.
The trial court relied heavily on the credibility of Pablo Sumandig’s testimony despite noted delays in his affidavit, which were satisfactorily explained.
The trial court dismissed the alibi of Renejane—who claimed to have stayed behind at a relative’s house—finding it unconvincing against positive identifications by prosecution witnesses.
Aggravating circumstances noted included treachery, abuse of superior strength, and an alleged outraging of the victims’ corpses, although not all of these factors were fully appreciated or qualifying under the law.

Whether the trial court erred in giving credence to Pablo Sumandig’s testimony given the delay in executing his affidavit of identification.
Whether the defense witness Epifania Riponte’s testimony could negate Sumandig’s claim regarding his presence at Barangay Lamesa on November 1, 1981.

Whether the accused’s claim of having remained at Nick Laborte’s mother’s house and his continued work in Cebu City, contrasting with the immediate flight of other co-accused, sufficiently exonerated him.

Whether the trial court appropriately assessed the circumstances that aggravated the crime, including the use of treachery and the alleged additional wounds inflicted after the victims’ death.
The proper qualification of factors such as abuse of superior strength and outraging the dignity of the victims, particularly in light of the evidence presented.

Whether the trial court’s conclusion regarding the identity and participation of the accused was properly supported by the cumulative evidence, despite discrepancies in witness statements.