Title
People vs. Sy Pio alias Policarpio de la Cruz
Case
G.R. No. L-3827-28
Decision Date
Nov 23, 1951
Sy Pio stole a revolver, shot and killed two individuals, and was convicted of murder qualified by treachery, receiving reclusion perpetua.

Case Digest (G.R. No. 224558)
Expanded Legal Reasoning Model

Facts:

  • Criminal Charges and Sentencing
    • Defendant: Sy Pio alias Policarpio de la Cruz.
    • Charged with murder in two separate informations filed before the Court of First Instance of Manila.
    • Found guilty in both cases and sentenced to reclusion perpetua, with accessory penalties including indemnification of P2,000 to the heirs of the deceased and payment of court costs.
  • The Incident Involving Ngo Chu and the First Victim
    • Ngo Chu, a Chinese owner of a sari-sari store, was the holder of a licensed revolver.
    • On the night of September 2, 1949, before going to bed, Ngo Chu ensured the revolver was loaded and hid it under his pillow.
    • The following morning, the revolver was discovered missing, prompting Ngo Chu to report the theft to a policeman and later to Police Precinct No. 1.
    • While en route to the precinct accompanied by his landlord, Celso Casingan, they encountered defendant Sy Pio on the street near a Chinese theater.
    • Following the defendant into a restaurant, Ngo Chu witnessed him carrying the revolver while verbally threatening in Chinese, “Don’t approach, otherwise I will shoot you or kill you.”
    • A shot was fired during this confrontation, resulting in the falling of a person later identified as Ong Pian.
    • Ngo Chu and Casingan pursued the defendant briefly but lost him and subsequently reported the shooting to the local police.
  • The Second Murder Incident
    • After the initial shooting, the defendant proceeded to Misericordia street.
    • At a house, he encountered Jose Sy, a Chinaman, who was reading a newspaper.
    • Without any verbal exchange, the defendant fired a shot at Jose Sy using the same revolver, resulting in the immediate death of Jose Sy.
    • Subsequent shots were fired in the air, after which the defendant fled the scene.
  • Apprehension and Confession
    • The defendant was apprehended in Tarlac several days later by members of the Philippine Constabulary.
    • Upon arrest, the defendant voluntarily made a written confession before the Justice of the Peace of Tarlac and the police officers in Manila.
    • His confession admitted that he shot Ong Pian and the other victim (Jose Sy) for personal reasons.
    • The written confession was signed by the defendant and supported by the factual circumstances.
  • Evidence and Corroboration
    • Multiple eyewitnesses provided testimony:
      • Ngo Chu and Celso Casingan (who observed the defendant in proximity and actions).
      • Francisca Luna (wife of Jose Sy) and Tan Chiong Kiap, both of whom corroborated the events.
    • The defendant attempted to offer an alternative narrative accusing a Chinese named Chua Tone and implicating two other individuals (Yu Owa and Lim Sy Puat), but these claims were uncorroborated and not supported by his confession.
    • The proper chain of evidence, consisting of eyewitness testimonies and the defendant’s own written declaration, conclusively established that the defendant was solely responsible for the murders.

Issues:

  • Whether the evidence on record, including eyewitness testimony and the written confession, is sufficient to establish the defendant’s guilt beyond reasonable doubt.
  • Whether the defendant’s alternative version implicating other individuals, which remains uncorroborated by his confession or other evidence, can offset the evidence presented by the prosecution.
  • Whether the admission of guilt by the defendant was voluntary and reliable in confirming his responsibility for the crimes.
  • Whether the qualification of murder as committed with treachery is properly applicable given the facts and circumstances of the killing.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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