Title
People vs. Ruiz
Case
G.R. No. 38715
Decision Date
Sep 15, 1933
Martin Noynay and Buenaventura Ruiz murdered Silvestre Arriesgado after a dispute over a carabao’s damage to crops; Ruiz’s alibi was disproven, leading to his conviction and modified sentence.

Case Digest (G.R. No. 38715)
Expanded Legal Reasoning Model

Facts:

  • Incident Background
    • On August 28, 1932, in the Municipality of Medellin, Cebu, a violent confrontation took place involving Silvestre Arriesgado, Martin Noynay, and Buenaventura Ruiz.
    • The incident stemmed from a dispute over a carabao owned by Martin Noynay that had allegedly destroyed sugar cane planted by the deceased Silvestre Arriesgado.
  • Sequence of Events
    • The Dispute Over Damages
      • The deceased caught the carabao and took it to Noynay’s residence, demanding payment for the sugar cane damages.
      • Martin Noynay, present at his house, denied any responsibility, claiming that his carabao was tied and therefore not liable.
      • The situation escalated when Arriesgado threatened to take the matter to the barrio lieutenant due to the non-payment.
    • The Chase and Attack
      • In response to the dispute, Noynay retrieved a spear from his house and, together with Buenaventura Ruiz, pursued the deceased.
      • Arriesgado attempted to flee but was overtaken under a tree approximately 82 meters from Noynay’s residence.
      • During the confrontation, Arriesgado’s 9-year-old son, Jose, witnessed the attack after hiding behind clumps of maguey.
  • Commission of the Crime
    • The Assault on Arriesgado
      • Martin Noynay stabbed Arriesgado in the shoulder with a spear as witnessed by Jose Arriesgado.
      • In a desperate response, Arriesgado threw a stone which struck Noynay on the forehead.
      • Noynay again attacked Arriesgado by stabbing him in the side.
      • Buenaventura Ruiz, the appellant, then declared “let us finish him” and proceeded to stab Arriesgado twice in the breast with a dagger.
    • Aftermath
      • The defendants quickly fled the scene: Noynay headed towards his house while Ruiz went in the direction of the provincial road.
      • Shortly after, Rosa Malinao, the wife of the deceased, arrived at the scene after being informed by her daughter Maria.
      • Upon inquiry, Jose, the young witness, confirmed that both Noynay and Ruiz had attacked and killed his father.
  • Evidence and Testimonies
    • Witness Testimonies
      • Jose Arriesgado provided direct testimony implicating both defendants in the murder.
      • Rosa Malinao, the wife of the deceased, corroborated seeing both defendants fleeing the scene.
      • Feliciano Pepito testified that he saw Ruiz heading towards Noynay’s house around noon.
      • Agripina de la Rama observed Ruiz moving from the scene towards the provincial road, directly refuting his alibi.
    • The Alibi of the Appellant
      • Buenaventura Ruiz claimed that at the time of the murder he was in a cockpit, 7 kilometers away from the scene.
      • Multiple witnesses’ accounts directly contradicted this claim, placing Ruiz at or near the scene of the crime.
  • Trial Court Decision
    • Charges and Verdict
      • Martin Noynay and Buenaventura Ruiz were charged with asesinato (homicide).
      • The evidence presented convinced the trial court that both defendants directly participated in the killing of Silvestre Arriesgado.
    • Sentencing and Mitigating Circumstances
      • The trial judge found the defendants guilty of homicide.
      • The court noted that the defendants were entitled to the benefit of two mitigating circumstances—provocation and obfuscation—under No. 4 and No. 6 of Article 13 of the Revised Penal Code.
      • Originally, both defendants were sentenced to eight years and one day of reclusion temporal, with an indemnity order to pay damages to the heirs of the deceased (amounting to P500) and the payment of court costs.
  • Appellate Proceedings
    • Assignments of Error Raised by Ruiz’s Attorney
      • The trial court erred by not declaring that the evidence did not establish, beyond a reasonable doubt, the guilt of Buenaventura Ruiz.
      • The preponderance of evidence was argued to be in favor of Ruiz, which, if not conclusive of his innocence, warranted his acquittal.
      • The lower court also failed to acquit Ruiz based on the principle of free proof, thereby justifying his appeal.
    • Reconsideration of the Evidence
      • The appellate court carefully re-evaluated all testimonial and material evidence.
      • It was noted that the physical evidence on the corpse of Arriesgado and multiple witness accounts were inconsistent with Ruiz’s alibi.

Issues:

  • Sufficiency of Evidence Against the Appellant
    • Whether the evidence presented in the trial court established, beyond reasonable doubt, the direct participation of Buenaventura Ruiz in the killing of Silvestre Arriesgado.
    • Whether the multiple witness testimonies, including that of the deceased’s son and spouse, adequately refuted the appellant’s alibi.
  • Validity and Application of Mitigating Circumstances
    • The appropriateness of applying the mitigating circumstances of provocation and obfuscation in the circumstances of the case.
    • Whether the actions of the deceased, that is, legally demanding payment for damages caused by the carabao, could justify any mitigating consideration.
  • Appellate Arguments on the Mode of Acquittal
    • Whether the trial court erred in not freely acquitting the appellant based on the available evidence and the rebuttal of his claimed alibi.
    • If the preponderance of evidence favored the appellant, should there have been a verdict of acquittal resting on the principle of doubt finding?

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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