Case Summary (G.R. No. L-1913)
Charges and Sentencing
The defendants were accused of murdering Lucio Balmes. The lower court found them guilty, attributing Jose Atienza and Ceferino Dagohoy to reclusion perpetua, while Hilarion Birador and Francisco Oyando received an indeterminate sentence of 10 years and 1 day of prision mayor to 17 years, 4 months, and 1 day of reclusion temporal. Moreover, all defendants were ordered to jointly indemnify Balmes's heirs with P2,000.
Prosecution's Theory
The prosecution asserted that, around 10:00 AM on April 28, 1946, Lucio Balmes and Antonio Contreras, joined by two Mangyans, attempted to enter private pasture land owned by Filemon Atienza. Upon arriving, the gate was found closed, which prompted Antonio to order Simon to open it. Following the opening of the gate, they allegedly encountered the defendants, who began firing at them. This shooting lasted about forty minutes. After the incident, Antonio crawled toward Lucio and discovered him wounded and covered in blood before reporting to the Chief of Police later that evening.
Defense's Position
The defense argued that none of the accused were present at the crime scene and had no familiarity with Lucio Balmes. They contended that Balmes came to Bulalakaw under the pretense of purchasing cattle and was subsequently murdered by Antonio Contreras and his associates. The defense claimed that the wounds found on Balmes indicated the manner of death was inconsistent with the prosecution's narrative.
Evidence Analysis
An examination of the body revealed two distinct injuries: a gunshot wound to the left breast and a blunt force injury to the jaw, suggesting that Balmes's death occurred under different circumstances than pervaded by the prosecution's claims. The presence of a blunt injury indicated that the murder involved some violence that was not accounted for within the prosecution's framework.
Questions of Credibility
The court found significant inconsistencies within the accounts of the prosecution witnesses, particularly regarding the actions and motivations of the defendants. The prosecution's narrative suggested behavior inconsistent with that expected of assailants intent on murder. The defendants’ actions—continuing to fire at Balmes for an extended period without effectively pursuing or eliminating witnesses—presented logical contradictions. Furthermore, the abandonment of Balmes's body at the crime scene contradicted an intention to conceal
...continue readingCase Syllabus (G.R. No. L-1913)
Case Overview
- In this case, the appellants Jose Atienza, Ceferino Dagohoy, Hilarion Birador, and Francisco Oyando were accused of the murder of Lucio Balmes on April 28, 1946, in Caguray, Bulalakaw, Mindoro.
- The lower court found the appellants guilty, sentencing Atienza and Dagohoy to reclusion perpetua, while Birador and Oyando received an indeterminate penalty due to the mitigating circumstance of lack of education. Each appellant was ordered to jointly and severally indemnify Balmes' heirs in the amount of P2,000.
Prosecution's Theory
- The prosecution’s narrative presented that at approximately 10 o'clock in the morning on April 28, 1946, Lucio Balmes and Antonio Contreras, along with two Mangyans, approached the pasture land belonging to Filemon Atienza.
- Upon reaching a closed gate near the Caguray river, Antonio instructed Simon to open it. As they entered, they noticed seven individuals, including the four appellants, approximately 30 brazas away.
- Following Antonio's call of "Pepe," Jose Atienza opened fire. Antonio observed Balmes fall to the ground. The appellants allegedly continued shooting for forty minutes.
- After the shooting ceased, Antonio crawled to Balmes, discovering him covered in blood, and later reported the incident to the Chief of Police in Bulalakaw at 10 o'clock that evening.