G.R. No. 129782 - People vs. Singh

On November 26, 1993, at about 7:30 in the morning in Barangay Canlalay, BiAan, Laguna, a group of ten Indian nationals, all surnamed Singh (including co-accused from whom only four were prosecuted), converged in front of the Mendiola Apartment.
The accused shouted in their native language and demanded that Surinder Singh come out of his apartment.
When Surinder Singh appeared, tensions escalated into violence, with the accused engaging in a coordinated attack.

Accused Dalvir Singh, among others, attempted an attack; when Surinder Singh stepped out, Dalvir initially tried to stab him.
The group then overpowered Surinder Singh: Dial Singh and Johinder Singh held his arms, Kuldip Singh pushed him on his back, and Dalvir Singh delivered a fatal stab to the right side of his stomach.
Following the stabbing, additional blows were delivered using lead pipes and other blunt instruments by Malkit Singh Dhillon and Jarnail Singh.

While the attack on Surinder Singh was unfolding and even as bail and motions were being intermingled with events, private complainant Dilbag Singh attempted to intervene.
During the struggle, Balwinder Singh stabbed Dilbag Singh on the left side of his back; Gurmok Singh also attacked him with a bolo but failed to cause further harm as Dilbag Singh managed to shift away.

Shortly after the incident, both injured parties were rushed to the Perpetual Help Hospital where Surinder Singh was pronounced dead on arrival.
Private complainants Dilbag Singh and Jaswinder Singh executed sworn statements detailing the incident, which became the basis for the complaint filed before the Municipal Trial Court (MTC) of BiAan.
Initially, charges were filed under homicide and frustrated homicide but were later upgraded to “Murder” for the killing of Surinder Singh and “Frustrated Murder” for the wounding of Dilbag Singh following the re-investigation prompted by motions from the complainants.
The case, originally assigned to the RTC Branch 24 of BiAan, Laguna, was later transferred to the RTC in San Pedro, Laguna due to various pre-trial motions, including petitions for bail, motion to inhibit, change of venue, and transfer of the accused between jails.
Among the ten accused Indians, only four – Balwinder Singh, Malkit Singh Dhillon, Mohinder Singh, and Dalvir Singh – were prosecuted; the remaining co-accused were at-large, except for Dial Singh, who died while in detention.

Appellant Dalvir Singh testified that during a confrontation with Jaswinder, Dilbag, and Surinder Singh, a physical altercation ensued when he was accused of informing on their status to immigration authorities.
According to Dalvir’s account, after a series of exchanges—comprising punches, slaps, and the retrieval of a pipe—he wrestled the knife from Surinder Singh during a struggle, which inadvertently resulted in Dilbag Singh being stabbed.
Corroborative evidence was offered by Wilfredo Rivera and SPO4 Manuel Francisco; Rivera’s testimony supported Dalvir Singh’s account, while Francisco’s testimony confirmed the execution of sworn statements by the private complainants.
Despite the defense’s claims of inconsistencies and a disputed version of events, the collective testimonies, including those directly from private complainants, established a narrative of coordinated violence against the victims.

Separate Informations were filed: Criminal Case No. 8683 for Murder and Criminal Case No. 8682 for Frustrated Murder.
During arraignment, some accused entered pleas of not guilty, while others were later arraigned.
After trial, the court found the guilt of the accused beyond reasonable doubt:

In Criminal Case No. 8683, the accused were convicted of murder and sentenced to reclusion perpetua.
In Criminal Case No. 8682, they were convicted of frustrated murder and sentenced to an indeterminate penalty ranging from 8 years and 1 day to 12 years and 1 day.

The court also ordered the accused to pay various amounts as civil indemnity, moral damages, attorney's fees, and costs, though some of these awards were later modified.

Whether the trial court erred by sanctioning procedural irregularities such as the admission of amended Informations without a proper preliminary investigation.
Whether the proceedings during the bail hearings and the subsequent delay in presenting evidence violated the accused’s right to a fair and speedy trial.

Whether the trial court erred in accepting the prosecution’s version of events over the testimonies of allegedly unbiased witnesses.
Whether the evidence from the bail hearings, automatically reproduced at trial, was appropriate and sufficient to establish guilt.

Whether the trial court’s award of damages—including hospitalization expenses, attorney’s fees, and compensation for lost earnings—was excessive and supported by evidence.
Whether the modifications in awarding damages, particularly the deletion of unsupported claims, were justified.

Whether appellant Dalvir Singh’s claim invoking self-defense, based on his account of events, was sufficiently proven to warrant acquittal or mitigation of charges.

Whether the trial court properly managed the congestion of motions, petitions, and transfers, and whether such delays justified any prejudice to the accused’s right to be heard.