Title
People vs. Sube
Case
G.R. No. 146034
Decision Date
Apr 9, 2003
Three individuals are convicted of homicide, not murder, as the Supreme Court finds insufficient evidence for premeditation despite credible testimony linking them to the crime.
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Case Digest (G.R. No. 146034)

Facts:

  • The case involves the People of the Philippines as the plaintiff-appellee against accused-appellants Lastide A. Sube, Rolando M. Menzon, and Felizardo Ontog, with co-accused Dino G. Ayala and Benedicto A. Acala still at large.
  • The incident occurred on February 14, 1993, in Pasong Palanas, Antipolo, Rizal.
  • Julio Solis and his brother Nicanor were at home when Julio heard shouts and laughter outside, including a threat directed at him.
  • Julio saw five armed individuals entering their yard and attempted to wake Nicanor, who was ill.
  • After failing to wake Nicanor, Julio hid and witnessed the accused entering their house and later saw Nicanor being struck with an airgun.
  • The accused emerged from the house carrying Nicanor, whose hands were bound; this was the last sighting of him alive.
  • Julio reported the incident to their father and the police, leading to the arrest of Sube and Menzon.
  • An information for murder was filed against Sube and Menzon on March 8, 1993, later amended to include other accused.
  • The prosecution alleged conspiracy to kill Nicanor with evident premeditation and treachery.
  • The accused claimed they were coerced into assisting in burying the body.
  • The Regional Trial Court found Sube, Menzon, and Ontog guilty of murder, sentencing them to reclusion perpetua and damages to the victim's heirs.

Issue:

  • (Unlock)

Ruling:

  • The trial court's conviction of the accused-appellants for murder was upheld, as their guilt was proven beyond reasonable doubt.
  • The evidence presented was sufficient to establish the conspiracy among the accused-appellants.
  • The trial...(Unlock)

Ratio:

  • The Supreme Court noted that trial court findings on credibility are generally binding unless significant facts are overlooked or misinterpreted.
  • Julio Solis's testimony was credible and detailed, positively identifying the accused and recounting events leading to Nicanor's death.
  • Inconsistencies in the accused-appellants' testimonies weakened their defense, as they attempted to shift blame to co-accused who were not present.
  • Circumstantial evidence can suffice for conviction if it meets specific criteria, which was satisfied in ...continue reading

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