Case Digest (G.R. No. L-31938)
Facts:
The case involves Rogelio Segales as the defendant-appellant and the People of the Philippines as the plaintiff-appellee. The incident occurred on the evening of May 11, 1963, during a dance at the public market in barrio Consolacion, Sogod, Southern Leyte, coinciding with the selection of a beauty queen. Around 9:00 PM, a commotion erupted when Gorgonio Tinio stabbed Hilarion Sesbrenio, witnessed by Cornelio Supot, who fled the scene in fear. Shortly after, Rogelio Segales stabbed Dionisio Oclaman in the left chest with a hunting knife, also witnessed by Supot and Ruperto Cadano. Oclaman fell to the ground, bleeding profusely. His stepbrother, Marcos Taba, arrived shortly after and, upon asking Oclaman who had stabbed him, received the response "Rogie." Oclaman was later found dead, and an autopsy revealed a stab wound that punctured his heart, leading to death from severe hemorrhage and shock.
Segales denied the charge, claiming he was playing bingo when Oclaman...
Case Digest (G.R. No. L-31938)
Facts:
Incident at the Dance Hall
- On the evening of May 11, 1963, a dance was held at the public market of barrio Consolacion, Sogod, Southern Leyte, to select a beauty queen.
- Around 9:00 PM, a commotion occurred when Gorgonio Tinio stabbed Hilarion Sesbrenio. This was witnessed by Cornelio Supot, who fled the scene along with others. Tinio was chased by Pat. Tomas Daclan, a member of the Municipal Police Force.
Second Stabbing Incident
- Shortly after the first incident, Rogelio Segales stabbed Dionisio Oclaman in the left chest with a hunting knife. This was also witnessed by Cornelio Supot, who saw Oclaman fall to the ground, bleeding profusely.
- Ruperto Cadano also witnessed the stabbing and demonstrated how Segales thrust the knife into Oclaman.
Aftermath of the Stabbing
- Marcos Taba, Oclaman’s stepbrother, arrived at the scene and asked Oclaman who stabbed him. Oclaman identified "Rogie" (Rogelio Segales) before dying.
- The body was autopsied by Dr. Ranulfo Salazar, who found a fatal stab wound to the left chest, puncturing the heart and causing severe hemorrhage and shock.
Defense’s Version
- Rogelio Segales denied the charge, claiming he was playing bingo when Oclaman approached him, saying he was stabbed by "Gorgor" (Gorgonio Tinio). Segales claimed he ran away after seeing Oclaman fall.
- Defense witnesses, including Tranquilino Duran and Marcelino Mainit, testified that Tinio was the one who stabbed Oclaman. Mainit claimed Tinio admitted to stabbing two persons while swimming in the sea.
- Corazon Segales, the defendant’s mother, testified that Oclaman came to her store, showed his wound, and blamed "Gorgor" before going to the bingo game.
Issue:
- (Unlock)
Ruling:
- (Unlock)
Ratio:
Credibility of Prosecution Witnesses:
- The Court found the testimonies of Cornelio Supot and Ruperto Cadano credible. Supot directly witnessed Segales stabbing Oclaman, and Cadano demonstrated how the stabbing occurred.
- Marcos Taba’s testimony about Oclaman’s dying declaration identifying Segales as the assailant was given weight as a dying declaration, which is admissible in evidence.
Inconsistencies in Defense’s Evidence:
- The defense’s claim that Gorgonio Tinio stabbed Oclaman was contradicted by Dr. Salazar’s findings. The wound was caused by a double-bladed weapon, while Tinio’s bayonet (Exhibit "5") was single-bladed.
- The defense witnesses’ testimonies were deemed unreliable. For instance, Marcelino Mainit’s story about Tinio swimming with the bayonet was considered implausible, as an assailant would likely dispose of the weapon.
Lack of Ill-Motive:
- The prosecution witnesses had no reason to falsely accuse Segales. The fact that they reported the incident to the Philippine Constabulary instead of the local police (where Segales’ father-in-law was the Chief of Police) further supported their credibility.
Treachery:
- The Court found that the attack was sudden and unexpected, qualifying the crime as murder with treachery. Segales’ act of stabbing Oclaman without warning ensured the victim had no opportunity to defend himself.
Indemnity:
- The Court increased the indemnity to P30,000.00, consistent with prevailing jurisprudence on damages for wrongful death.