Title
People vs. Vinas
Case
G.R. No. L-21756
Decision Date
Oct 28, 1968
Jesus Varela was stabbed from behind in 1962; brothers Nelson and Norman Vinas were convicted of murder based on credible eyewitness testimony, conspiracy, and Norman's weak alibi. Supreme Court upheld the conviction.
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Case Digest (G.R. No. L-21756)

Facts:

Incident Details

  • On the evening of April 10, 1962, Jesus Varela was stabbed from behind while urinating beside a tree in the premises of the Bacolod Murcia Sugar Central.
  • The autopsy revealed a stab wound four inches from the spine, at the level of the second lumbar vertebra, which penetrated the peritoneal region and lacerated the vena cava, causing severe hemorrhage and shock leading to death (Exhibit "B").

Arrest and Charges

  • The investigation led to the arrest and prosecution of brothers Nelson and Norman Vinas, along with Rodolfo Sumpay, who had been living with the Vinas brothers for over two months before the killing.
  • The charge against Sumpay was dismissed, and he was utilized as a prosecution witness.
  • After trial, both brothers were convicted of murder and sentenced to reclusion perpetua, with an order to indemnify the heirs of Jesus Varela with P6,000.00 and to pay the costs.
  • Only Norman Vinas appealed the decision.

Prosecution’s Evidence

  • Two eyewitnesses, Rodolfo Sumpay and Mario Derla, testified against the accused.
    • Sumpay testified that Nelson Vinas informed him of their plan to kill Varela, and Norman Vinas urged them to stab Varela, claiming Varela had wronged him.
    • Derla corroborated Sumpay’s testimony, stating that Nelson Vinas stabbed Varela from behind while he was urinating.
  • Varela’s widow testified that Norman Vinas had previous altercations with her husband, including a fight in December 1961 that led to Norman’s demotion at the Central.

Defense’s Version

  • The defense claimed that Varela attacked Sumpay with a knife, and Nelson Vinas intervened to defend Sumpay, accidentally stabbing Varela.
  • Norman Vinas presented an alibi, stating he was in Hinigaran attending a birthday party on April 9 and did not return to Bacolod until April 11.
  • The defense failed to explain how Varela could have been stabbed from behind in a frontal encounter or why Varela would attack three men without provocation.

Trial Court’s Findings

  • The trial court found the defense’s version implausible and relied on the testimonies of Sumpay and Derla, who were closely acquainted with the accused.
  • The court concluded that both brothers conspired to kill Varela.

Issue:

  • (Unlock)

Ruling:

  • (Unlock)

Ratio:

  1. Credibility of Witnesses: The Court found the testimonies of Sumpay and Derla credible, despite minor contradictions, as such inconsistencies are natural in recalling a startling event. The witnesses’ close relationship with the accused made their testimonies more reliable, as they had no apparent motive to falsely accuse the Vinas brothers.
  2. Conspiracy: The Court agreed with the trial court’s finding of conspiracy based on the brothers’ presence at the scene, their remarks to Sumpay before the crime, and Nelson Vinas’s act of stabbing Varela without personal motive.
  3. Alibi: Norman Vinas’s alibi was deemed insufficient. The Court noted that Hinigaran was only 50 kilometers from Bacolod, making it physically possible for him to have been present at the crime scene. Additionally, no credible explanation was provided for his extended stay in Hinigaran beyond the birthday celebration.
  4. Defense’s Implausibility: The defense’s version of events was inconsistent with the physical evidence, particularly the stab wound from behind, and failed to explain why Varela would attack three men without provocation.


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