Case Digest (G.R. No. 119544)
Facts:
People of the Philippines v. Edgar Umadhay y Trabasas, Sergio Umadhay y Trabasas and Albert Umadhay y Trabasas, G.R. No. 119544, August 03, 1998, Supreme Court Third Division, Kapunan, J., writing for the Court.The information charged the three Umadhay brothers with murder for the November 16, 1992 killing of Gonzalo Jaranilla III in Oton, Iloilo. At arraignment the accused pleaded not guilty and trial on the merits proceeded in the Regional Trial Court (Branch 38) of Iloilo City. The trial court found the brothers guilty beyond reasonable doubt, sentenced each to reclusion perpetua and ordered payment of civil indemnity (P50,000) and actual damages (P22,711). The accused appealed to the Court but the appeal was elevated to the Supreme Court under Rule 45 (petition for review on certiorari).
On the night of the killing the victim attended a wake, left about 10:15 p.m., and walked toward his home accompanied briefly by Cenon Rosal. After returning to his house the victim’s wife, Cecilia Gealon Jaranilla, saw from about three meters away Albert fire a long firearm at the victim’s back; the victim fell, and then Edgar and Sergio (armed with short firearms) and Albert approached and fired additional shots, including to the head. Neighbors Rosal and “Kardo” found the victim alive but dying; while being taken to the hospital the victim identified his assailants as “Edgar, Sergio and Alberto all surnamed Umadhay.” He was pronounced dead on arrival.
Police investigation followed Cecilia’s identification; Edgar initially invoked his right to remain silent but later admitted participation and offered to surrender a firearm; Albert led police to firearms hidden near and behind the victim’s house; paraffin tests later showed nitrates on Edgar but not Albert. At trial Edgar claimed self-defense and gave a version that the victim had confronted him with a shotgun and grenade, fired once, and in the ensuing struggle the victim accidentally shot himself; Edgar said he later took the .38 revolver and hid it. Albert and Sergio denied involvement and set up alibis.
Two postmortem examinations were conducted: rural physician Dr. Vicente Carreon noted three fatal wounds (left aural, lower chin slug fragment, and a pugakhang wound with powder burns at right lumbar area). Medico-legal officer Dr. Tito Doromal detailed three bullet wounds to the head/neck with powder burns on one wound indicating close range, and a thoraco‑abdominal pellet wound in the posterior lumbar region with recovered wad and pellets consistent with a 20‑gauge shotgun; he opined that the head wounds were caused from the left side and that grappling could not explain the multiple head wounds and posterior pellet wound.
The trial court credited Cecilia’s eyewitness testimony and the victim’s dying dec...(Subscriber-Only)
Issues:
- Did the trial court err in admitting and relying on the victim’s dying declaration and the prosecution’s evidence to establish guilt beyond reasonable doubt?
- Did Edgar establish proof of self‑defense to justify acquittal?
- Did appellants validly establish voluntary surrender as a mitigating circumstance?
- Should the defenses of alibi and simple denial by Albert and Sergio prevail over the pro...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
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Doctrine:
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