Case Digest (G.R. No. 110405)
Facts:
On April 25, 1982, at approximately 6:00 PM, the brothers Domingo and Dominador Nepal were near the store of Merly Pelago in Barangay San Isidro, General Luna, Quezon. Present at the store were Barangay Captain Pacito Agoncillo and several others, including Ruben Agoncillo, who were engaged in a drinking spree. While Dominador went to a nearby house, Domingo was called over by Ruben. Dominador soon heard shouts from the store and rushed back, witnessing a confrontation where Jesus Lachica was kicking Ruben Agoncillo, with Domingo attempting to pacify the situation.
As the evening progressed, Domingo and Dominador decided to leave, but Ruben, who was intoxicated, insisted they accompany him to complain to Barangay Captain Agoncillo. They declined and proceeded home. As they walked, they were ambushed by Virgilio TaAedo, Berlito Lachica, Danilo Mercadal, and others, all armed with bladed weapons. Danilo struck Domingo on the head with a bolo, and Virgilio delivered a fatal t...
Case Digest (G.R. No. 110405)
Facts:
Incident Overview:
- On 25 April 1982, at 6:00 PM, Domingo and Dominador Nepal passed by Merly Pelago’s store in Barangay San Isidro, General Luna, Quezon. A group, including Barangay Captain Pacito Agoncillo and others, were drinking at the store. Berlito Lachica and Danilo Mercadal were present but not drinking.
Initial Altercation:
- Domingo was called by Ruben Agoncillo, while Dominador went to Nemesio del Mundo’s house. Dominador heard shouts from the store and saw Jesus Lachica kicking Ruben Agoncillo. Domingo intervened to pacify them.
- Danilo Mercadal attempted to hack Domingo with a bolo, but Domingo defended himself with a piece of wood. Berlito Lachica, also armed, followed Danilo toward the mountain.
The Attack:
- At around 7:00 PM, as Domingo and Dominador were leaving, Ruben asked them to accompany him to Barangay Captain Agoncillo. They declined and left Ruben with Boy Revadavia.
- While walking home, Domingo was attacked by Virgilio TaAedo, Berlito Lachica, Jesus Lachica, Enrico Gepaya, and Mercurio Lemina, all armed with bladed weapons. Danilo Mercadal struck Domingo on the head, and Virgilio delivered the final blow with a balisong.
- Dominador shouted for help, but Domingo was left bleeding profusely and later died from his injuries.
Witness Testimonies:
- Maxima Remuyan, Domingo’s mother, witnessed the attack from about five meters away and identified the assailants.
- The accused (except Virgilio TaAedo) testified in court, denying involvement and presenting alibis. Defense witnesses, including Myrna Barretto and Sofio Pollo, provided conflicting accounts.
Trial Court Decision:
- On 14 December 1990, the trial court convicted all accused of murder, sentencing them to 12–20 years of imprisonment and ordering them to indemnify Domingo’s heirs with P30,000.
Appeal to the Court of Appeals:
- The Court of Appeals affirmed the conviction but modified the penalty to reclusion perpetua and increased the indemnity to P50,000. The case was elevated to the Supreme Court for review.
Issue:
- (Unlock)
Ruling:
- (Unlock)
Ratio:
Credibility of Witnesses: The trial court’s findings on witness credibility are entitled to great weight, as it had the opportunity to observe their demeanor. The defense’s alibis were deemed weak and insufficient to prove their absence from the crime scene.
Conspiracy and Treachery: The accused acted in concert, lying in wait and attacking Domingo simultaneously with bladed weapons. This ensured the killing without risk to themselves, qualifying the crime as murder with treachery.
Nature of the Crime: The attack was not a casual encounter but a planned assault. The accused’s coordinated actions and the victim’s inability to defend himself established treachery, which qualified the crime as murder under Article 248 of the Revised Penal Code.