Case Summary (G.R. No. L-36662-63)
Events Leading to the Crime
On February 17, 1970, the defendant, after consuming alcohol, fatally stabbed Pascua with a bolo, inflicting wounds that caused instantaneous death. Following this, Camano proceeded to attack Buenaflor, who was kneeling at the gate of his house, delivering multiple blows that resulted in his immediate death. Both victims were neighbors of the accused, with a history of animosity stemming from an altercation three years prior related to fishing.
The Trial and Defense
Camano was charged with murder, which he denied, claiming self-defense in the death of Buenaflor while disputing his involvement in Pascua's death. His narrative included a supposed unprovoked attack by the victims and contended that he reacted out of necessity to protect himself. However, the trial court found the self-defense claim unconvincing due to inconsistencies in his testimony and lack of supporting evidence.
Court Findings and Conclusions
The trial court determined that the killings exhibited evident premeditation, treachery, and abuse of superior strength. It dismissed Camano's defense as incredible and refuted claims that the killings were impulsive or lacking premeditated intent. The court found that despite prior altercations, there was insufficient evidence that a premeditated plan had existed till the moment of the murders took place.
Arguments on Appeal
On appeal, Camano's counsel contested the murder charges, arguing for a reduction to homicide based on a lack of evident premeditation and treachery. The argument focused on the nature of the encounter being spontaneous rather than planned. The court noted that evident premeditation requires clear intent, and neither Camano’s prior hostility nor his declarations when intoxicated sufficed to establish a calculated intent to kill on the day of the incident.
Treachery and Aggravating Circumstances
The court held that the method of attack on both victims was treacherous, given that Pascua was stabbed from behind and Buenaflor was attacked while in a vulnerable position. The argument that the circumstance of intoxication should mitigate Camano's review was entertained but ultimately deemed irrelevant to changing the foundational findings of guilt.
Conclusion and Sentencing
Ultimately, the court affirmed the convictions for murder, but modified the sen
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Case Overview
- The case involves Filomeno Camano, who was charged with the murder of two victims, Godofredo Pascua and Mariano Buenaflor, resulting in a mandatory review of the death sentence imposed by the Court of First Instance of Camarines Sur.
- The incident took place on February 17, 1970, in the barrio of Nato, Municipality of Sagnay, Province of Camarines Sur.
Facts of the Case
- Filomeno Camano, after consuming liquor, stabbed Godofredo Pascua twice with a bolo, resulting in immediate death.
- Following the attack on Pascua, Camano proceeded to hack and stab Mariano Buenaflor multiple times, also resulting in instant death.
- The autopsy reports detailed the nature of the wounds sustained by both victims, confirming the fatal injuries inflicted by Camano.
Relationship and Motive
- The victims and the accused were neighbors living on the same street, and there had been previous misunderstandings stemming from a fishing incident three years prior.
- Camano harbored resentment against both victims after a refusal to assist him with his fishing boat, leading to a personal vendetta.
- Despite appearing cordial at times, particularly when drinking with Pascua, the relationship was reportedly strained, especially between Camano and Buenaflor.
Events Leading to the Incident
- On the day of the incident, Camano was reportedly drinking and later encountered the two vict