Case Digest (A.C. No. 11870)
Facts:
The case revolves around two appellants, Ruben Victoriano (alias Vicks) and Pacifico Pineda (alias Edison), who, along with a co-defendant Segundo Serrano (who remained at large), were accused of the murder of two individuals, Pio Silos, Jr. and Damaso Luanzon, committed on July 22, 1944, in Sibul, a sitio in the barrio of Manibaug-Pasig, Porac, Pampanga. The trial was held before the Court of First Instance of Pampanga where Judge Antonio G. Lucero presided. The events leading to the incidents unfolded after Pablo Ayson reported to Fernando Tolentino, a Huk leader, that Silos and Luanzon had stolen his cawas. Subsequently, on a dark night before July 22, two unidentified men sought Silos and Luanzon at the house of Pio Silos, Sr., leading to their eventual abduction. On the evening of July 22, 1944, several members of the Huk group, including Esteban Basilio and Segundo Serrano, took both victims to a secluded area where they were interrogated and brutally assaulted. Both Silo
Case Digest (A.C. No. 11870)
Facts:
- Case Background and Parties
- The case involves the People of the Philippines as plaintiff and appellee against appellants Ruben Victoriano (alias Vicks) and Pacifico Pineda (alias Edison), with Segundo Serrano (alias Ferrer) also implicated and still at large.
- The accused were former members of the Hukbalahap organization and were involved in separate but related murder cases concerning the deaths of Pio Silos, Jr. and Damaso Luanzon.
- The crimes were committed on July 22, 1944, in the sitio of Sibul, barrio of Manibaug-Pasig, municipality of Porac, Pampanga, amid suspicions arising from theft allegations.
- Chain of Events Leading to the Murders
- Motive and Preliminary Accusations
- On July 1944, Pablo Ayson, after losing his vats (cawas), suspected Pio Silos, Jr. and Damaso Luanzon of the theft because they had previously shown interest in buying them.
- Eladio Ayson, Pablo’s son, then reported the matter to Fernando Tolentino, a Huk leader in the barrio, requesting the apprehension of the alleged thieves.
- The Abduction and Interrogation
- On a dark night prior to the incident, two unknown men visited the residence of Pio Silos, Sr. seeking Pio Silos, Jr. and Damaso Luanzon, indicating an earlier coordinated effort.
- At approximately 8:00 p.m. on July 22, 1944, Huk members Esteban Basilio (alias Rustin) and Segundo Serrano (alias Ferrer) brought Manuel Austria and Lucerio Arceo to an isolated spot in Sibul for grave digging.
- The Sequence of the Killings
- Ruben Victoriano and Pacifico Pineda later arrived dragging Damaso Luanzon, whose hands were tied, to the same location.
- The accused interrogated Damaso Luanzon regarding the theft of Ayson’s vats; upon his denial, he was physically assaulted with fists and subsequently struck repeatedly with an iron bar by Segundo Serrano on orders by Pacifico Pineda, rendering him unconscious.
- Following the abuse, Damaso Luanzon was pushed into an open pit.
- Shortly thereafter, Pacifico Pineda signaled other Huk members, and Pio Silos, Jr. was also apprehended with his hands tied.
- Pio Silos, Jr. was similarly interrogated and, after denying the accusations, was beaten on the stomach by multiple assailants.
- As his condition deteriorated, the accused proceeded to drag, assault, and finally throw his body into the pit, where grave-diggers were ordered to hastily cover the grave even though the victims were still breathing.
- Post-Crime Developments
- The bodies of both victims were exhumed on June 19, 1946, after being discovered by Lucerio Arceo, and were subsequently identified by relatives and constabulary personnel.
- During the investigation, appellant Ruben Victoriano gave an affidavit detailing the events and confessing to his participation, including an admission of administering blows to Pio Silos, Jr. under duress.
- Evidence and Testimonies
- The testimony of the grave-diggers Manuel Austria and Lucerio Arceo carried significant weight in confirming the sequence of events and the nature of the crimes.
- Although the appellants provided defenses regarding their roles—in particular, claims of passive observation or absence due to illness—the trial court found these explanations unconvincing in light of the consistent evidence.
- Invocation of Amnesty Proclamations
- As a last resort, the appellants invoked Guerrilla Amnesty Proclamation No. 8 (September 7, 1943) and Huk Amnesty Proclamation No. 76 (June 21, 1948) to seek relief from criminal liability.
- The trial court, after scrutinizing the evidence—including testimonies disputing claims of espionage and “buy and sell” activities—the court ruled that the victims were neither Japanese spies nor involved in nefarious trade, thus invalidating the amnesty defense.
- Legal and Factual Findings
- Evidence Sufficiency
- The corroborative evidence, in particular the confession of Ruben Victoriano and the consistent accounts from key witnesses, was held to prove the appellants’ guilt beyond reasonable doubt.
- Testimonies by affiliated Huks who were close to the accused were weighed against the independent accounts of non-affiliated witnesses such as Dominador Chantengco, whose evidence further discredited the appellants’ claims.
- Discrediting of the Amnesty Defense
- The court clarified that Amnesty Proclamation No. 76 did not cover crimes committed during the Japanese occupation, as such crimes were already remedied by earlier proclamations.
- Furthermore, the specific crimes confessed were not those of rebellion, sedition, or illegal association but the violent murders of two civilians.
Issues:
- Sufficiency of Evidence
- Whether the combined evidence, including testimonies and confessions, established the guilt of the appellants beyond reasonable doubt.
- Whether the physical and testimonial evidence corroborated the sequence of events leading to the murders.
- Applicability of the Amnesty Proclamations
- Whether Guerrilla Amnesty Proclamation No. 8 is applicable in absolving the appellants for the crimes committed during the Japanese occupation.
- Whether Huk Amnesty Proclamation No. 76, intended for post-liberation political dissent, could be extended to cover the violent offenses charged in this case.
- Credibility of Witnesses and Defendants’ Claims
- The reliability of the confession of appellant Ruben Victoriano in light of the evidence.
- The veracity of the defense claims of passive involvement or non-participation by the appellants, particularly the claim of Pacifico Pineda regarding his illness.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)