Case Digest (G.R. No. L-1795-6)
Facts:
The People of the Philippines v. Pedro Valdez, G.R. Nos. L-1795-6, May 23, 1949, Supreme Court En Banc, Montemayor, J., writing for the Court.The appellant, Pedro Valdez, was tried jointly in the Court of First Instance of Tarlac in criminal cases Nos. 130 and 143 for the murder of Jose Teodoro, Jr. and Jose Teodoro, Sr. The trial court found Valdez guilty in both cases and sentenced him in each to reclusion perpetua with the legal accessories, ordered him to indemnify the heirs of each deceased P2,000, and imposed costs, with the proviso that the total period of both penalties should not exceed forty years. Valdez appealed to the Supreme Court.
The factual background, as found by the trial court and recited by this Court, is that on the night of March 5–6, 1946, armed intruders entered the Teodoro household through the kitchen and fired at least five shots from a Thompson sub-machine gun, killing Jose Teodoro, Jr. instantly and mortally wounding Jose Teodoro, Sr., who died the next day despite surgery. Members of the household — notably 15-year-old Felipe de Guzman — saw, by the light of a miner’s lamp belonging to Teodoro, a man whom Felipe positively identified as the appellant, wearing a khaki shirt and short pants and holding a Thompson aimed at Teodoro, Sr. Teodoro, Sr., while in grave condition at the provincial hospital and believing he would die, told his uncle Dr. Juan Nepomuceno that he had recognized Pedro Valdez as one of the assailants; this statement was treated as a dying declaration. Mrs. Maria Lasam (the elder Teodoro’s wife) saw, by lamp light, a man of the same height and build as Valdez hurrying toward the kitchen and found her son already dead.
Police arrested Valdez at his home wearing a bloodstained khaki shirt and short pants; a search uncovered two hand-grenades hidden under the chicken roost. At the Teodoro house authorities found the miner’s lamp (Exhibit E), a trigger pin of a hand-grenade (Exhibit H), an unexploded grenade, three empty .45 caliber shells that laboratory analysis showed were fired from a Thompson sub-machine gun, and a denim cap not belonging to the household. The prosecution established motive as a private grudge arising from a dispute over Valdez’s share of the rice harvest he cultivated as a tenant of Jose Teodoro, Sr.
Valdez offered an alibi that he was asleep at home the entire night; the trial court rejected it. Two barrio officials called by the defense testified that Teodoro, Sr. and Felipe told them they did not know who the assailants were, but the trial court discredited this testimony and accepted why Teodoro, Sr. had limited the disclosure of the assailant’s identity. During appeal counsel for Valdez also filed a petition for dismissal invoking the benefits of Proclamation No. 76 (series of 1948) and Secretary of Justice Circular No. 27; the Solicitor General opposed. The Supreme...(Subscriber-Only)
Issues:
- Is Pedro Valdez covered by Proclamation No. 76 (series of 1948) and its implementing Secretary of Justice Circular No. 27, entitling him to dismissal by amnesty?
- Does the evidence — including eyewitness identification, the dying declaration of Jose Teodoro, Sr., physical exhibits, and motive — sustain the convictions for murder?
- What is the proper penalty and civil indemnity in light of the q...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)