Case Digest (G.R. No. L-1795-96)
Facts:
People of the Philippines v. Pedro Valdez, G.R. Nos. L-1795-96, May 23, 1949, the Supreme Court En Banc, Montemayor, J., writing for the Court.The People (plaintiff-appellee) charged Pedro Valdez (defendant-appellant) in two criminal cases (Nos. 130 and 143) for the March 5–6, 1946 killings of Jose Teodoro, Sr. and his son Jose Teodoro, Jr. The two cases were tried jointly because the two victims were killed on the same occasion. The trial court found Valdez guilty in both cases and sentenced him in each to reclusion perpetua with the legal accessories, ordered indemnity of P2,000 to the heirs of each deceased, and fixed that the total period of both penalties should not exceed forty years.
The prosecution’s evidence described a night-time forced entry through the kitchen door into the Teodoro home; shots were fired from a Thompson sub-machine gun, killing Jose Teodoro, Jr. instantly and mortally wounding Teodoro, Sr., who died the next day despite surgery. Young Felipe de Guzman (15) testified he saw two men by the kitchen door by the light of Teodoro Sr.’s miner’s lamp and fully recognized the front man as Valdez, who wore a khaki shirt and short pants and was holding a Thompson. Mrs. Maria Lasam (Teodoro Sr.’s wife) saw a man in the yard with a gun, heard the struggle and shots, and briefly saw a man’s back who appeared to be of the same height and build as Valdez. Teodoro Sr., while at the hospital and believing he would die, told his uncle Dr. Juan Nepomuceno that he had recognized Pedro Valdez as one of the assailants; the Court treated this as a dying declaration.
Police arrested Valdez at his home wearing a bloodstained khaki shirt and short pants; a search produced two hand-grenades under the chicken roost. Authorities recovered at the Teodoro sala a miner’s lamp belonging to Teodoro, a trigger pin of a hand-grenade, an unexploded hand-grenade, three empty .45-caliber shells which ballistics showed were fired from a Thompson sub-machine gun, and a denim cap not belonging to the family. The motive advanced was a private grudge arising from a dispute over Valdez’s share of a rice harvest (Valdez demanding an 80% share against the Teodoros’ lower offers); Valdez was a tenant and member of the PKM (a local association).
Valdez pleaded alibi, claiming he slept at home the entire night. Two defense witnesses (Sonsa and Tabugan, barrio lieutenant and deputy lieutenant) testified that when they arrived early March 6th they were told Teodoro Sr. and Felipe did not know the assailants; the trial court rejected this testimony as not credible and because the purported declarations were not transmitted to authorities to exculpate Valdez. The trial court convicted; on appeal to this Court Valdez also invoked Proclamation No. 76 (1948) — a presidential amnesty — and sought dismissal under it. The Solicitor General opposed the amnesty claim.
The Supreme Court reviewed the evidence, rejected application of Proclam...(Subscriber-Only)
Issues:
- Is the appellant entitled to dismissal under Proclamation No. 76 (series of 1948) and the implementing circular of the Secretary of Justice?
- Does the evidence establish the appellant’s guilt for murder beyond reasonable doubt, and what qualifying or aggravating circumstances affect the proper penalty?
- Is the trial court’s award of indemnity approp...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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