Title
People vs. Resureccion
Case
G.R. No. L-38730
Decision Date
Dec 14, 1979
Inmate Suliman Santiago was stabbed to death by fellow inmates in New Bilibid Prison. Accused claimed alibi, but witness testimony led to their conviction for homicide, not murder, due to insufficient proof of treachery and premeditation.

Case Digest (G.R. No. 162401)
Expanded Legal Reasoning Model

Facts:

  • Background of the Case
    • The case is an automatic review of the decision dated April 26, 1974, of the Circuit Criminal Court of Pasig, Rizal, which imposed the death penalty on the accused for the crime of murder.
    • The decision was rendered in Criminal Case No. 1327 and later modified to a conviction for homicide.
    • The case was reviewed en banc under G.R. No. L-38730 on December 14, 1979.
  • Incident and Circumstances
    • On March 25, 1971, at around 3:00 p.m., prisoner Suliman Santiago, an inmate at the New Bilibid Prison in Muntinlupa, Rizal, was fatally stabbed in front of the prison boxing office.
    • The initial attack occurred in an alley between the Education Section and the Commander’s Office, where Santiago was first stabbed; he was then chased and stabbed again in front of the boxing office.
    • The victim sustained multiple stab wounds, three of which were determined to be mortal, as identified in the Necropsy Report by Dr. Ricardo G. Ibarrola.
  • Charges and Allegations
    • The accused – Danilo Resurreccion, Romeo Maranan, and Amador Atienza – were charged with the crime of murder under Article 248 of the Revised Penal Code.
    • The information, dated April 17, 1973, asserted that the accused acted in concert, conspiring and confederating with evident premeditation and treachery while armed with improvised deadly weapons.
    • It was alleged that the assault was committed with treachery as the victim was attacked from behind in a manner that left him with little to no opportunity for defense.
  • Testimonies and Evidence
    • Prosecution’s Principal Witness:
      • Rogelio Bulalayao, an inmate serving time for theft and homicide, testified that he observed the accused engaging in suspicious behavior and later saw them attacking Suliman Santiago.
      • He noted that Danilo Resurreccion drew a deadly weapon (described as “yaring bilibid”) and stabbed Santiago, with subsequent coordinated attacks by Maranan and Atienza.
    • Corroborative Testimony by Defense Witness:
      • Gilberto Llamoso, another inmate, corroborated that he saw Romeo Maranan stab Santiago from behind with a bladed weapon.
      • Llamoso confirmed that other accomplices were also armed with similar improvised weapons.
    • Additional Evidence:
      • The Necropsy Report identified the mortal wounds and described them as inflicted by sharp, double-bladed instruments, though not conclusively establishing if one such instrument was used or if multiple weapons were involved.
      • Eye-witness accounts provided details concerning the movement and behavior of the accused before, during, and after the crime.
  • Accused’s Defense and Alibi
    • All three accused professed their innocence and claimed they were in Dormitory 4-C at the time of the stabbing, with the dormitory padlocked.
    • They asserted that they were together in the dormitory and were unaware of Santiago prior to the incident.
    • Testimonies from one of the accused revealed inconsistencies regarding the time and process of the transfer from Dormitory 4-B to Dormitory 4-C.
  • Aggravating Circumstances and Final Findings at Trial
    • The trial court noted the presence of aggravating circumstances such as abuse of superior strength, given that the accused were armed while the victim was unarmed.
    • With respect to Romeo Maranan, his previous conviction for frustrated murder was considered an aggravating factor (recidivism).
    • Although the prosecution cited treachery and evident premeditation as qualifying circumstances, the trial court found insufficient evidence to sustain these specific allegations.
    • The court concluded that the coordinated assault, supported by credible eyewitness testimonies, indicated a common design to kill, thereby convicting the accused of homicide rather than murder.

Issues:

  • Credibility of Witness Testimonies
    • Whether the testimony of Rogelio Bulalayao, despite his status as a convict, should be given significant credence in light of corroborative evidence.
    • The extent to which the testimony of Gilberto Llamoso corroborated Bulalayao’s identification of the accused as the perpetrators.
  • Validity of the Accused’s Defense and Alibi
    • Whether the collective alibi provided by the accused, asserting that they were confined in Dormitory 4-C at the time of the crime, can effectively counter the positive identification by the witnesses.
    • The implications of the conflicting accounts regarding the timing of their transfer between dormitories.
  • Presence of Qualifying and Aggravating Circumstances
    • Whether the elements of treachery and evident premeditation were sufficiently established to uphold a conviction for murder.
    • The proper application of aggravating circumstances such as abuse of superior strength and recidivism (specifically regarding Romeo Maranan) in determining the appropriate penalty.
  • Classification of the Crime
    • Whether the crime, as committed by the accused, should be classified as murder or homicide based on the available evidence and the elements present during the commission of the offense.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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