G.R. No. L-23463 - Republic vs. Clemente

Case Digest (G.R. No. L-23463)
Expanded Legal Reasoning Model

Facts:

Incident and Victim’s Injuries

On February 5, 1962, at about 3 o’clock in the afternoon, Reyes Matnog, barrio lieutenant of MacArthur, Lavezares, Samar, sustained multiple injuries at the corner of the national highway and the barrio road in front of Hospicio Tan’s house in barrio San Miguel.
Reyes Matnog had just returned from a celebration party (blow-out) in honor of Pedro Baniega’s election as barrio lieutenant of San Miguel.
The Rural Health Officer of Lavezares, in his autopsy-report (Exh. A), recorded the following external and internal injuries:

Multiple stab wounds at various parts of the body: a stab on the left lower part of the upper third of the arm (penetrating through and entering the chest cavity); a stab wound on the posterior right side of the umbilical region (penetrating the abdominal cavity); and a stab wound above the right scapular region.
A lacerated wound over the left scapular region causing fracture of the supra-scapular bone.
Fractures in the lower third of the left humeral bone and the third left medial rib.
Approximately one liter of blood accumulated in the left chest cavity with injury to the left side of the heart leading to profuse hemorrhage.

The medical opinion confirmed that Reyes Matnog died from profuse internal hemorrhage leading to shock.

Investigation and Preliminary Evidence

The investigation was spearheaded by the Chief of Police of Lavezares, Victorino F. de Leon.
Evidence collected included:

A crime-scene sketch (Exh. D) based on affidavits of Basilio Pornelos and Isabel Medala.
Affidavits by Pornelos (executed February 6, 1962) and Medala (executed February 8, 1962), implicating the three Clemente brothers in the killing.

On February 7, 1962, a formal complaint was filed against Carlos, Pascual, and Rosalio Clemente by the Chief of Police.

Charges and Prosecution’s Case

On March 15, 1962, the three brothers were charged before the Court of First Instance of Samar (Crim. Case No. C-778) with:

Murder for Carlos and Pascual Clemente, due to their alleged participation in stabbing Reyes Matnog while he was defenseless and prone on the ground.
Homicide for Rosalio Clemente, based on his admitted attack, although his claim of self-defense was put into question.

The prosecution presented several pieces of evidence including:

Testimonies by Dr. Antonio Ofiana on the cause of death.
Identification testimony by Chief of Police Victorino F. de Leon through the crime-scene sketch.
Testimony of Pablito Seriguini, an eyewitness, who recounted the sequence of attacks and identified the assailants.

The trial testimonies established that:

Rosalio first engaged Reyes Matnog during a quarrel, stabbing him with a double-bladed hunting knife.
As Reyes attempted to flee, after having been initially attacked, both Pascual and Carlos allegedly joined the assault, slashing and stabbing the prostrate victim.
Some inconsistency and gaps existed in Seriguini’s account; however, it was deemed “clear, positive and devoid of signs of artificiality” by the trial court.

Defense Presentation and Alibi Claims

The defense argued:

Carlos Clemente’s alibi: He claimed to have left home with Gerardo Panes in the morning to gather firewood in San Agustin, returning by banca at about 7 o’clock in the evening, corroborated by Panes.
Pascual Clemente’s statement: He was at home with his child, left upon hearing a commotion, and only encountered Rosalio near the crime scene, advising him to go home.
Rosalio Clemente’s version: He encountered Reyes at Hospicio Tan’s house; after an exchange in which Reyes threatened him, Reyes lunged at him with a hunting knife, prompting Rosalio to retaliate.

Additional defense witnesses included:

Gerardo Panes, who corroborated Carlos’s stated whereabouts.
Roman Esplana and Bartolome Unay, who testified that Rosalio alone inflicted the fatal wounds.

The defense attempted to undermine the credibility of eyewitness Seriguini by alleging inconsistencies and oscillations in his testimony.

Court’s Findings at Trial

The trial court concluded that:

All three accused participated in the killing of Reyes Matnog.
The fatal wounds, especially being inflicted on a defenseless, prostrate victim, constituted murder, with a special emphasis on the treachery shown by the sudden attack.

Specific findings included:

Carlos and Pascual were implicated in the attack despite their alibi, based largely on the demeanor and the perceived lack of credibility in their testimonies.
Rosalio’s claim of self-defense was rejected due to autopsy findings indicating wounds inflicted from behind.

Penalties imposed:

Carlos and Pascual Clemente were sentenced to reclusion perpetua for murder qualified by treachery.
Rosalio Clemente, having been charged with homicide, received a sentence of imprisonment ranging from a minimum of 12 years (prision mayor) to a maximum of 17 years, 4 months and 1 day (reclusion temporal).
They were also ordered to indemnify the heirs of Reyes Matnog for damages totaling monetary amounts for loss of earning capacity, moral damages, and costs.

Appellate Considerations

All three accused appealed the decision citing:

Inconsistencies in the credibility of eyewitness Seriguini.
Issues regarding the alibi and the alleged contradictory evidence provided by the defense witnesses.

The appellate court examined:

The eyewitness testimony and the consistency of Seriguini’s affidavit.
The prior accounts of the witnesses and the autopsy findings.

Ultimately, the appellate court maintained that:

While Rosalio Clemente was the principal culprit, his voluntary surrender mitigated his liability.
Carlos and Pascual, whose participation was not definitively proven and whose defenses were inconsistent, were to be considered mere accomplices.

Issues:

Credibility and Consistency of Eyewitness Testimonies

Whether the testimony of Pablito Seriguini, despite admitted deficiencies, provided sufficient and credible evidence for the direct involvement of all three accused.
The impact of the demeanor and inconsistencies in the testimonies of defense witnesses (including Gerardo Panes, Roman Esplana, and Bartolome Unay) on the overall case.

Sufficiency of the Alibi Presented by Carlos and Pascual Clemente

Whether the alibi of being in a distant barrio gathering firewood, corroborated by Gerardo Panes, could definitively exonerate Carlos from the crime.
The logical credibility of the circumstances surrounding their return and subsequent actions.

Self-Defense Claim of Rosalio Clemente

The validity of Rosalio’s claim that his actions were in self-defense against an aggressive Reyes Matnog.
Whether the autopsy findings (showing wounds inflicted from behind) and the circumstances of the attack sufficiently negated a self-defense argument.

Degree of Participation and Criminal Liability

Determining if the participation of Carlos and Pascual in the attack amounted to murder or if, due to uncertain involvement, they were merely accomplices.
Whether the absence of evidence showing prior conspiracy or premeditation changed the categorization of the crime from murder to homicide in the case of Rosalio.

Mitigation and Sentencing Considerations

Whether Rosalio Clemente’s voluntary surrender, despite the initial appearance of culpability, warranted a reduction in his sentence.
The appropriateness of applying the Indeterminate Sentence Law in reducing the penalties for all three accused.

Ruling:

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Ratio:

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Case Digest (G.R. No. L-23463)
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Case Digest (G.R. No. L-23463)
Expanded Legal Reasoning Model