G.R. No. 205623 - Sonley vs. Anchor Savings Bank

On December 25, 1994, at approximately 4:00 in the afternoon, Pablito Tambis y Baliong was involved in a violent encounter in barangay Hagbuaya, Catigbian, Bohol.
Prior to the incident, the accused was seen drinking with friends at his residence and was known to get drunk regularly.
After a session of drinking, the accused, armed with bolos (kitchen cutlasses), proceeded to the house of Leonardo Tagsa y Bibat, a physically handicapped individual suffering from a mental disorder.

According to the information filed on March 21, 1995 by the second assistant city prosecutor, the accused, displaying intent to kill, used three long sharp-pointed bolos to hack and decapitate the victim.
The act was described as one executed with treachery, taking advantage of the victim’s weakness, and in a manner that intentionally augmented the victim’s pain.
After decapitating the victim, the accused was reported to have paraded the severed head in the neighborhood, an act aimed at outraging the sensibilities of the public.

He saw the accused carrying two bolos as he ascended the victim’s house.
Upon noticing an approaching motorcycle, the accused ordered its driver to stop and punctured its tires, effectively preventing the witness from seeking immediate help.
Shortly thereafter, from a distance, he observed the accused carrying the victim's severed head and proclaiming it as Leonardo Tagsa’s head.

Confirmed that the accused had flagged down his motorcycle near the victim’s residence.
Testified that after puncturing the motorcycle’s tires, the accused returned to the victim’s house and later emerged carrying the decapitated head.

The severed head of Leonardo Tagsa was found approximately 100 meters away from his house.
The cause of death was determined to be irreversible shock secondary to homicidal decapitation.
The victim’s subsequent wake and burial incurred expenses, for which the accused was later ordered to indemnify the victim’s heirs.

During his arraignment on October 10, 1995, the accused pleaded guilty to the murder charge.
He admitted, under cross-examination, to having decapitated Leonardo Tagsa.
Post-crime, the accused took refuge in a vacant house in the same barrio and voluntarily surrendered to the police the following day, turning over both bolos—the one he had admitted carrying and the additional weapon allegedly taken from the victim.

The trial court conducted an extensive inquiry into the voluntariness and full appreciation of the consequences of the accused’s plea of guilty, given the gravity of the offense.
The court received and evaluated circumstantial evidence and witness testimonies which established:

The accused’s deliberate use of excessive force against a physically disadvantaged victim.
The presence of aggravating circumstances, notably the abuse of superior strength.

Notwithstanding the evidence of abuse of superior strength, the trial court recognized the mitigating circumstances of voluntary surrender and the plea of guilty.
Consequently, the trial court convicted the accused of murder, originally imposing the death penalty along with orders to pay indemnity and actual damages to the victim’s heirs.

On automatic review, the accused challenged the trial court’s sentencing, contending that his admission, voluntary surrender, and guilty plea warranted a penalty reduction.
The issue raised was whether the aggregate of mitigating circumstances sufficiently merited replacing the death penalty with the lesser penalty of reclusion perpetua, notwithstanding the aggravating circumstance of abuse of superior strength.

Whether the trial court correctly appreciated and weighed the mitigating circumstances of voluntary surrender and the plea of guilty against the aggravating circumstance of abuse of superior strength.

Did the voluntary surrender and plea outweigh or mitigate the gravity of the crime sufficiently to warrant a reduction in penalty from death to reclusion perpetua?
Was there an error in dismissing the presence or effect of the aggravating circumstance of abuse of superior strength, particularly given the method of the crime and the victim’s physical condition?

Whether circumstantial evidence and the presented testimonies were adequate to sustain a conviction for murder beyond reasonable doubt.

Is the chain of circumstantial evidence, as presented by multiple prosecution witnesses, sufficient to rule out any reasonable hypothesis of innocence?
Does the evidence sufficiently void the need for direct observation of the crime, especially concerning the alleged treachery in the method of attack?

Whether the trial court properly identified and applied legal standards regarding the qualification of the offense as murder under Article 248 of the Revised Penal Code, particularly in view of the acts of decapitation and public display of the victim’s head.