G.R. No. L-26241 - People vs. Vicente

Case Digest (G.R. No. L-26241)
Expanded Legal Reasoning Model

Facts:

Incident and Victim Details

On the night of 29 October 1965, Jaime Mariano Soriano was attacked in front of the public market in Asingan, Pangasinan.
The deceased sustained multiple wounds, as documented in the autopsy report:

A crescent-shaped flap wound on the right anterior parietal area of the scalp.
A 2.5 cm stab wound over the left cheek exposing the cheek bone.
Five stab wounds in the chest and stomach, with two cutting major heart vessels and injuring the lungs.
An additional stab wound penetrating the right thoracic cage.
Other wounds on the left arm, right hand, occipital area, neck, and back, including lacerations and scratches.

The stab wounds were inflicted with different sharp-edged instruments; notably, a broken bottle caused the flap wound and a blunt instrument might have caused the occipital wound.
The time of death was determined to be between 7:00 and 8:30 p.m. on the day of the incident, with shock from severe hemorrhage cited as the cause.

Circumstances Surrounding the Crime

On 29 October 1965, Jaime Soriano, along with Florentino Arellano and eyewitness Virgilio Sarmiento, was at a local store buying cigarettes.
Accused Jose Vicente allegedly confronted Soriano with an incriminating question in Ilocano regarding his association with Boy Canaveral, following a prior incident involving the shooting of an individual known as Manong Idio.
Almost immediately after Soriano denied the allegation, Jose Vicente produced a dagger and stabbed him repeatedly.
Ernesto Escorpizo, a companion of Vicente, attacked Soriano with a small knife while the victim was already on the ground.
Accused Alfredo Bedonio and Ambrocio Cabiles, Jr. were reported to have engaged in further violent actions by throwing stones at the prostrate victim and, at a later point, at witnesses.

Evidence and Statements

The prosecution’s evidence largely relied on the eyewitness testimony of Virgilio Sarmiento.

Sarmiento identified the accused—Jose Vicente, Ernesto Escorpizo, Alfredo Bedonio, and Ambrocio Cabiles, Jr.—as the perpetrating assailants based on a statement he executed immediately after the crime.
His testimony was corroborated by physical evidence including the number, direction, and nature of the wounds sustained by Soriano.

Multiple extra-judicial confessions were recorded:

Statements allegedly executed by Jose Vicente, Ernesto Escorpizo, and Ambrocio Cabiles, Jr. before local authorities.
These statements were later used to supplement the eyewitness account and establish the sequence of events.

The testimony reflected both the immediate reaction of the witnesses and subsequent recantations or denials under different circumstances:

For instance, during the wake, a statement was made by the father of the deceased suggesting that Sarmiento had denied knowing the assailants, though this did not detract from his earlier identification.

Defendant’s Alibi and Defence Evidence

The accused presented an alibi claiming they were not present at the scene of the crime at the time of the stabbing.

Accused Ambrocio Cabiles, Jr. testified that he was at the Pantranco station in Urdaneta at approximately 7:30 p.m. on the day of the incident.
Accused Alfredo Bedonio claimed to have been at a canteen in Urdaneta, drinking beer with Ernesto Escorpizo, with their movements corroborated by statements regarding their departure from the canteen.
Jose Vicente testified that he had visited his wife and child in barrio Camantiles before rejoining his companions later that evening.

The defense argued that, based on their alibis, the accused were not present or involved in the attack on Soriano.

Arrest, Interrogation, and Subsequent Proceedings

On 30 October 1965, following the incident, a criminal complaint was filed in the Municipal Court of Asingan.
The police, acting promptly on Sarmiento’s identification, arrested the four accused in barrio Dumampot.
During their detention, several of the accused were made to sign statements—which they later claimed were executed under duress and without a full understanding of the contents.
The information filed on 18 April 1966 charged the accused with conspiring to kill Jaime Soriano by inflicting multiple wounds with treachery.

Charges and Court Proceedings

The case was prosecuted as murder with the killing characterized by treachery due to the unexpected and sudden nature of the attack.
In its decision on 8 June 1966, the Court of First Instance of Pangasinan found all four accused guilty of murder.
The accused received varied sentences:

Jose Vicente was sentenced to life imprisonment.
Ernesto Escorpizo was sentenced, as an accomplice, to a term ranging from 10 years and 1 day up to 17 years and 4 months.
Alfredo Bedonio and Ambrocio Cabiles, Jr. were acquitted on the ground of reasonable doubt.

Additional orders included the mandate for joint and several indemnification of P12,000.00 to the heirs of Jaime Soriano and allocation of the court costs.

Issues:

Credibility of Witnesses

The primary issue presented on appeal was the degree of credence to be accorded to the testimony of eyewitness Virgilio Sarmiento.
Consideration was given to whether the extra-judicial confessions of the accused—particularly those of Jose Vicente, Ernesto Escorpizo, and Ambrocio Cabiles, Jr.—were tainted by procedural irregularities, such as being signed without the full awareness of the contents.

Evaluation of the Alibi Defence

The defense contended that the accused had established an alibi that separated them from the crime scene.
The issue revolved around whether the alibi and inconsistent statements from the accused should have lessened the weight of Sarmiento’s positive identification.

The Role of Corroborative Physical Evidence

An issue also arose regarding the reliability of physical evidence, specifically the autopsy findings and the nature of the wounds, to support or refute the testimonies.
This required balancing the testimonial evidence with forensic findings to determine if they collectively established the guilt of the accused.

Ruling:

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Ratio:

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Doctrine:

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Case Digest (G.R. No. L-26241) Core Legal Reasoning Model Expanded

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Case Digest (G.R. No. L-26241) Expanded Legal Reasoning Model

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Case Digest (G.R. No. L-26241)
Core Legal Reasoning Model

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Case Digest (G.R. No. L-26241)
Expanded Legal Reasoning Model