Case Summary (G.R. No. L-49808)
Charges and Initial Ruling
The complaint detailed that the accused, armed and acting in concert, attacked and ultimately killed Mrs. Tiaga after forcibly engaging in sexual assault against her will. The Circuit Criminal Court in Bacolod City, after trial, found them guilty of murder beyond reasonable doubt but acquitted them of rape due to reasonable doubt regarding that charge. As a result, the court imposed the death penalty owing to the aggravating circumstances present.
Appeal and Review Process
Due to the imposition of the death penalty, the case was automatically elevated to the Supreme Court for review. Various briefs were submitted by the accused and the Solicitor General, with natural complications arising from changes in law, particularly the abolition of the death penalty under the 1987 Constitution.
Withdrawal and Status of Appeals
Appellant Julio Gumban filed a motion to withdraw his appeal, which was granted. His case was remanded to the lower court for judgment execution, automatically commuting his death sentence to reclusion perpetua. The court then required the remaining appellants to declare their intentions regarding their appeals. Only Montano and Posadas expressed their desires to pursue their cases, while Aquino's failure to respond resulted in the dismissal of his appeal.
Prosecution's Evidence and Defense Claims
The prosecution's case was built upon testimonies from six witnesses, including family members and law enforcement. Conversely, the appellants mounted a defense of alibi, claiming they were engaged in other activities some distance away during the time of the murder. The trial court, however, favored the prosecution's evidence, emphasizing the credibility of witnesses and the lack of convincing evidence for the alibi.
Assessment of Evidential Claims
In their appeal, the appellants contended that the trial court improperly attributed evident premeditation to their actions. They argued that the court relied on circumstantial evidence and inferences rather than direct, corroborated proof of planning or conspiracy. The Supreme Court acknowledged that qualifying circumstances such as evident premeditation must be established by direct evidence and cannot rest solely on assumptions or presumptions.
Treachery as a Qualifying Circumstance
The Supreme Court found that while evident premeditation was not proven, treachery was adequately established through the spontaneous and violent execution of the crime, where the victim was caught off-guard and totally defenseless. The accused had disguised their intent under the pretense of relational familiarity and ambushed the victim. This conclusion supported the court’s classification of the offense as murder rather than homicide.
Conspiracy and Aggravating Circumstances
The evidence supporting the existence of a conspiracy among the accused was deemed sufficient, with acts demonstrating shared intent to assault the victim. The trial court's findings of aggravating circumstances, including disregard f
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Case Citation
- G.R. No. L-49808
- February 26, 1988
- 241 Phil. 1006
Parties Involved
- Plaintiff-Appellee: The People of the Philippines
- Defendants-Appellants: Arnulfo Aquino, Alfredo Posadas, Jr. (alias "Fred"), Julio Gumban, Jeffrey Montano
Background of the Case
- The accused were charged with the crime of "Murder with Rape," which was alleged to have occurred on December 9, 1972, in Ilog, Negros Occidental, Philippines.
- The information detailed a brutal attack on Mrs. Inocencia M. Tiaga, listing multiple severe injuries leading to her death, including:
- Complete fracture of the radius and ulna in the left forearm.
- Fracture of the frontal bone of the skull.
- A four-inch incised wound to the neck involving major blood vessels.
- Additional stab wounds and contusions.
Procedural History
- The Circuit Criminal Court of Bacolod City found all four accused guilty of murder but acquitted them of rape due to reasonable doubt.
- The trial court imposed the death penalty, which initiated an automatic review by the Supreme Court due to the gravity of the sentence.
Developments in the Appeal
- Appellants filed their briefs at various dates, leading to a consolidated brief from the Solicitor General.
- Julio Gumban withdrew his appeal, resulting in a remand of his case for execution of judgment, with the death sentence commuted to reclusion perpetua due to the abolition of the death penalty under the 1987 Constitution.
- Jeffrey Montano and Alfredo Posadas, Jr. expressed their desire to continue the appeal, while Arnulfo Aquino'