Facts:

The case involves the appeal of Lorenzo Ruzol, who was found guilty of murder by the Court of First Instance of Quezon. The incident occurred on August 5, 1954, in Sitio Calisetan, Barrio of San Luis, Municipality of Baler, Subprovince of Aurora, Province of Quezon. The victim, Juan Andal, was asleep in his home with his family, including his son Eladio, when he was attacked. Eladio was awakened by a sound resembling the cutting of a coconut and saw Ruzol standing beside his father. Upon noticing his father was injured, Eladio opened a window and recognized Manuel Torres outside. Both Ruzol and Torres fled the scene together. Eladio sought help from a neighbor and reported the incident to the Philippine Constabulary, identifying Ruzol and Torres as the assailants.

An autopsy revealed that Juan Andal died from severe head injuries caused by a sharp instrument, likely a hatchet. Witnesses, including Eladio and Dominga Eugenio, corroborated the events leading to the murder, i...

Facts:

Background and Incident

• Juan Andal, a married man, lived in Sitio Calisetan, Barrio of San Luis, Municipality of Baler, Subprovince of Aurora, Province of Quezon, in 1954.
• On the night of August 5, 1954, Juan Andal and his family, including his 11-year-old son Eladio, were asleep in their small house.
• Eladio was awakened by a sound resembling the cutting of a coconut. He saw Lorenzo Ruzol standing beside his father, who was wounded on the head.
• Eladio recognized Ruzol and later saw Manuel Torres outside the window. Both Ruzol and Torres fled towards Torres' house.
• Eladio pursued them, shouting for help, and later reported the incident to the Philippine Constabulary.

Investigation and Autopsy

• The Philippine Constabulary investigated the crime. Ruzol and Torres were brought to the scene of the crime, where they shuddered upon seeing the victim's body.
• An autopsy revealed that Juan Andal died from a severe head injury caused by a sharp instrument, likely a hatchet, which caused a skull fracture and brain damage.

Testimonies and Evidence

• Eladio Andal testified that he recognized Ruzol and Torres due to the light from a kerosene lamp in the room.
• Dominga Eugenio, a witness, corroborated Eladio's testimony, stating that Ruzol and Torres had confessed to killing Juan Andal.
• The motive for the crime was linked to a dispute over land and personal relationships. Juan Andal's wife was allegedly Ruzol's paramour, and there had been an altercation between Juan Andal and Manuel Torres earlier that day.

Defense Arguments

• Ruzol and Torres denied involvement in the crime, claiming they were at home that night.
• They explained their trembling at the crime scene as a reaction to the gruesome sight of the victim's body.
• Ruzol denied any romantic involvement with Juan Andal's wife.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Identification of the Accused: Eladio Andal's testimony was credible and corroborated by other evidence, including the autopsy report and Dominga Eugenio's testimony. The rapid identification of the accused and the sequence of events supported the reliability of Eladio's account.
2. Weapon Used: The nature of the wounds indicated the use of a hatchet, which aligned with Eladio's testimony and the evidence found at Torres' house.
3. Aggravating Circumstances: The Court agreed with the trial court that the crime was committed with the aggravating circumstances of dwelling, nighttime, and abuse of superior strength. However, it ruled that dwelling could not be absorbed by treachery, while nocturnity and abuse of superior strength were included in the qualifying circumstance of treachery.
4. Penalty: Due to the lack of sufficient votes for the death penalty, the Court imposed reclusion perpetua as the appropriate penalty for the crime of murder.