Facts:

The case involves the People of the Philippines as the plaintiff-appellee against Rogelio Sansaet y Santojala, Silverio Sansaet y Santojala, and Leopoldo Sansaet y Santojala as the accused-appellants. The incident occurred on June 25, 1989, in a hut owned by Marcelo Tumaob located in Barangay Igtugas, Tobias Fornier, Antique. On that day, approximately sixteen individuals were gathered, consuming "atubaa" (a local alcoholic beverage) and enjoying "pulutan" (snacks) after working in the rice fields. During the gathering, a joke about a long penis led to a heated exchange between Leopoldo Sansaet and Uldarico de Castro, with Leopoldo making a provocative remark involving Uldarico's wife. This incited Uldarico, resulting in a confrontation where both he and Rogelio Sansaet drew their bolos (machetes) and began to fight.

As the altercation escalated, Silverio and Leopoldo joined Rogelio in attacking Uldarico, inflicting multiple wounds on him. Despite U...

Facts:

Context of the Incident:
On June 25, 1989, around 5:30 PM, at a hut owned by Marcelo Tumaob in Barangay Igtugas, Tobias Fornier, Antique, approximately 16 individuals, including the accused and the victim, Uldarico de Castro, were drinking tubaa (a local alcoholic beverage) after working in the rice fields. The group was engaged in merrymaking when a joke about a "long penis" arose.

The Joke and Escalation:
Leopoldo Sansaet joked about Silverio Sansaet having a long penis, but Uldarico de Castro insisted his friend had a longer one. Leopoldo then made a provocative remark involving Uldarico’s wife, which angered Uldarico. This led to a verbal altercation between the two.

The Confrontation:
Rogelio Sansaet challenged Uldarico, saying, "Why, are you brave? Go downstairs." Both Rogelio and Uldarico armed themselves with bolos and went downstairs, where they began hacking each other. Uldarico was struck on the base of his ear, while Rogelio was hit on the bridge of his nose.

The Attack:
Silverio and Leopoldo positioned themselves behind Uldarico and hacked him on the nape and right shoulder. Uldarico retaliated, wounding Silverio on the left forearm. Rogelio then delivered a second blow, severing Uldarico’s hand as he tried to parry the attack. Uldarico fell to the ground and rolled toward the river.

The Final Assault:
Leopoldo and Rogelio followed Uldarico to the river, where they continued hacking him multiple times. Leopoldo declared, "To, we will just kill him," and Silverio was restrained by his wife. After confirming Uldarico’s death, the three brothers left the scene.

Aftermath:
The incident was reported to the barangay captain by Jovito Sansaet and Herminio Mondragon. The Sansaet brothers surrendered to the police that evening, with Rogelio and Leopoldo turning over their bolos.

Issue:

• (Unlock)

Ruling:

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Ratio:

1. Credibility of Witnesses:

   • The Court held that the relationship of a witness to the victim does not automatically impair their credibility, especially when no improper motive is shown. Herminio Mondragon’s testimony was deemed credible despite his familial ties to the victim.
   • The delay in reporting the incident was not considered detrimental to the witness’s credibility, as fear of reprisals is a common reason for such delays.

2. Defense of Denial and Alibi:

   • The Court reiterated that denial and alibi are weak defenses, especially when contradicted by positive identification by credible witnesses.

3. Abuse of Superior Strength:

   • The prosecution failed to prove that the accused purposely used excessive force out of proportion to the means of defense available to the victim. The Court emphasized that mere numerical superiority does not constitute abuse of superior strength unless it is shown that the aggressors intentionally exploited their combined strength to overpower the victim.

4. Modification of the Crime:

   • Since the qualifying circumstance of abuse of superior strength was not proven, the crime was downgraded from murder to homicide.

Fallo

The Supreme Court set aside the trial court’s decision and found the accused guilty of homicide under Article 249 of the Revised Penal Code. Each accused was sentenced to an indeterminate penalty of 10 years of prision mayor (minimum) to 17 years and 4 months of reclusion temporal (maximum). They were also ordered to pay the heirs of Uldarico de Castro P50,000 as civil indemnity, P21,000 for funeral expenses, and P50,000 as moral damages.