Case Summary (G.R. No. L-34089)
Applicable Law
The case is analyzed under the Revised Penal Code and the provisions of the 1935 Philippine Constitution, as it predates the 1987 Constitution.
Incident Summary
On September 1, 1970, the defendants allegedly conspired to murder Mario San Juan, inflicting 18 stab wounds and 12 hacking wounds with bladed weapons. The Circuit Criminal Court of Pasig, Rizal, convicted the defendants and sentenced them to death along with accessory penalties, including financial indemnity to the heirs of San Juan.
Testimonies from Prosecution
The prosecution's case relied heavily on the testimonies from several witnesses: Dario Nalagan, a Senior Medico-Legal Officer, who confirmed the post-mortem findings and categorized the wounds as indicative of multiple assailants; Rafael Atizado, a police sergeant, who described the investigations leading to the defendants' arrests; and Alberto Fernandez, a key eyewitness, who identified the defendants during the assault on San Juan.
Eyewitness Account
Fernandez testified that he, along with San Juan and another companion, encountered the defendants while they were drinking at a bakery. Upon trying to avoid a confrontation, San Juan was attacked unexpectedly. Fernandez described the brutal nature of the assault in which he and his companion were unable to assist San Juan, leading to his eventual death.
Defense Claims
The defense strategy hinged on denying the defendants' involvement and presenting alibis. Each accused claimed to be at different locations during the incident. For instance, Candado claimed he was driving his calesa during the time of the assault, while Sadie asserted he was working in the market. Maglalang claimed he was out of town.
Issues of Alibi
The court found the defense of alibi to be weak. The testimonies presented by the defense were not corroborated by credible evidence and were undermined by the positive identification of the accused by eyewitnesses. The court reiterated that for an alibi to be valid, it must not only establish that the accused was elsewhere but demonstrate the impossibility of being at the scene of the crime.
Assessment of Credibility
The trial court found the testimonies of the prosecution witnesses, particularly that of Fernandez, credible and compelling. The court emphasized that the suddenness and severity of the attack qualified it as treachery, as San Juan was ambushed while trying to escape.
Conspiracy and Collective Responsibility
The court concluded that conspiracy among the defendants was evident, as they acted cohesively and with a common objective during the assault. The presence of multiple individuals wielding weapons in a premeditated a
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Case Overview
- This case involves an automatic review of the decision rendered by the Circuit Criminal Court, Seventh Judicial District, Pasig, Rizal, in Criminal Case No. CCC-VII-464-P.C., where the defendants were charged with murder.
- The incident occurred on September 1, 1970, resulting in the death of Mario San Juan, who was allegedly attacked by the defendants in a conspiracy to kill him.
Charges and Sentencing
- The amended information charged the defendants with murder, specifically citing conspiracy, treachery, and evident premeditation as elements of the crime.
- The trial court convicted the defendants, sentencing each to death and imposing accessory penalties, along with monetary damages to the heirs of the deceased amounting to P12,000, P10,000 in moral damages, and P10,000 in exemplary damages.
Prosecution's Evidence
- The prosecution relied on testimonies from several witnesses:
- Dario Nalagan: A Senior Medico-Legal Officer who conducted a post-mortem examination on the victim, revealing 18 stab wounds and 12 hacking wounds, indicating multiple assailants.
- Rafael Atizado: A police sergeant who noted the victim's injuries and the subsequent identification of the defendants as part of the group responsible for the attack.
- Alberto Fernandez: The key witness who testified regarding the events leading to the murder, identifying the attackers and detailing the assault.
Testimony Highlights
- Nalagan's examination showed that:
- The wounds were inflicted by sharp instrum