G.R. No. L-25174 - People vs. Sibayan

The case involves an information charging Dionisio Sibayan (alias Isiong) along with co-accused, Pedro Moreno and Herminio Caspillo, for the killing of Lorenzo Grospe.
The crime allegedly occurred on the 7th of June, 1964 in the Municipality of Talugtog, Province of Nueva Ecija.
The prosecution’s indictment stated that the accused, in concert and with intent to kill, struck the victim repeatedly on the head with a piece of hard wood, causing his instantaneous death.

Multiple witnesses—chief of police Fidel Dumandan, surviving spouse Carmen Castillo, barrio captain Marceliano Caspillo, Alejandro Soriano, and patrolman Benjamin de Fiesta—identified Dionisio Sibayan as the assailant.
Testimonies by Alejandro Soriano and Benjamin de Fiesta were pivotal: Soriano observed Sibayan standing over the dying victim while de Fiesta saw Sibayan flee the scene and even attempted to chase him.
Marceliano Caspillo corroborated the evidence through the information relayed by Sibayan’s wife, Clarita Castillo, who admitted that her husband killed the victim despite her efforts to stop him.

Municipal Judge Alfredo Leybag notarized exhibit A, which was a sworn confession by Sibayan.
Judge Leybag confirmed that he inquired about the voluntariness of the confession and Sibayan acknowledged that the statements were true.
The content of the confession substantially recited Sibayan’s role in striking the victim’s head with a piece of wood.

After the crime, it was noted that in the early morning of June 8, 1964, both Sibayan and his wife disappeared from Talugtog.
The disappearance, especially of Sibayan who had familial ties with the victim, raised suspicion given the rural custom of attending a relative's burial.
The flight from the scene was seen as indicative of consciousness of guilt, as Sibayan left not only the immediate area but also did not stay for customary family obligations.

Upon due trial in the Court of First Instance of Nueva Ecija, Pedro Moreno and Herminio Caspillo were acquitted, while Dionisio Sibayan was found guilty.
The court sentenced Sibayan — on the basis of the prosecution’s evidence — to life imprisonment, indemnification to the victim’s heirs, and imposition of the accessory penalties provided by law.
Although the initial information alleged premeditation and treachery, the trial court did not sustain evidence to establish these as aggravating or qualifying circumstances.

Whether the cumulative testimony of the prosecution witnesses, including the identifications by Soriano, de Fiesta, and the admission by Sibayan’s wife, suffices to establish the guilt of Dionisio Sibayan for the killing of Lorenzo Grospe.

The credibility and reliability of the seven prosecution witnesses were juxtaposed with the appellant’s lone testimony, raising questions about the weight to be given to his statements.

Whether the sworn confession (exhibit A) should be deemed voluntary and reliable despite the appellant’s denial and the discrepancies between his court testimony and the contents of the confession.

The defense contested the voluntariness of the confession, while Judge Leybag testified that the confession was indeed given voluntarily and was accurate.

Whether the absence of evidence of the alleged aggravating circumstances of premeditation and treachery mandates a reclassification of the crime from murder to simple homicide.

The fact pattern does not support the necessary elements for premeditation and treachery, given that evidence pointed to a face-to-face altercation between Sibayan and the deceased.

The appropriateness of applying the Indeterminate Sentence Law to impose a penalty ranging from nine (9) years of prision mayor to sixteen (16) years of reclusion temporal in light of the reclassification of the offense.