Case Summary (G.R. No. L-37945)
Facts of the Case
The conflict between the Bilog brothers escalated into violence on April 28, 1971, after Jose Bilog resented his brother Douglas for receiving a larger share of inherited lands. Jose’s animosity led him to plot to kill Douglas. Early attempts to act on this were thwarted when Cervancia, a relative of Douglas, intervened. Subsequently, on a later occasion, Jose attempted to hire another individual, Nicasio Dayao, to assassinate Douglas but was turned down. The critical incident unfolded on April 19, 1972, where multiple witnesses, including Antonio Cabig, testified that following a drinking session, Jose Bilog initiated an attack on Douglas using a bladed weapon, which was joined by Canete, who also stabbed Douglas.
Witness Testimonies and Evidence
The testimony of Antonio Cabig played a significant role in establishing the sequence of events during the attack. Cabig witnessed both canete and Jose stabbing Douglas with a bladed instrument and noted the overwhelming force of the attack, which included multiple stab wounds resulting in Douglas’s death from severe hemorrhage. Furthermore, the forensic examination conducted by Dr. Oscar Magtang revealed a total of 26 injuries on Douglas Bilog's body, confirming the brutality of the attack.
Defendants’ Claims and Legal Arguments
Adriano Canete contested the validity of his extrajudicial confession, Exhibit "C," arguing that it was fabricated and inconsistent with other evidence. He claimed the absence of premeditation, contending that the acts committed could only amount to physical injuries or homicide at most. In contrast, Jose Bilog sought to refute the prosecution's case by challenging the credibility of witness Cabig and asserting an alibi, maintaining that he was engaged in household chores during the time of the incident.
Court’s Analysis and Rulings
In its analysis, the court emphasized the weight of Cabig's eyewitness account against the defendants' claims of alibi and lack of premeditation. The court found the participation of both defendants in a conspiracy to murder, which was characterized by treachery since the assault was sudden and left Douglas with no chance to defend himself. On the matter of the extrajudicial confession, the court ruled that it was made voluntarily and with no signs of coercion, thus upholding its admissibility.
Verdict and Sentencing
The court affirmed the decision of the lower court but modified the sentence from death to reclusion perpetua for both defendants due to a lack of necessary votes o
...continue readingCase Syllabus (G.R. No. L-37945)
Case Background
- The case involves the defendants, Adriano Canete and Jose Bilog, who were charged and convicted of murder by the Court of First Instance of Palawan.
- Both defendants were sentenced to the maximum penalty of death and ordered to pay the heirs of the deceased, Douglas Bilog, the sum of P12,000.00 without subsidiary imprisonment in case of insolvency, along with proportional costs.
Facts of the Case
- Jose Bilog and Douglas Bilog were brothers with a contentious relationship stemming from inheritance disputes over ricelands adjacent to the Inagawan Sub-Colony in Puerto Princesa, Palawan.
- On April 28, 1971, Jose attempted to kill Douglas with his father's shotgun, which was thwarted through intervention by family members.
- In May 1971, Jose offered a prisoner, Nicasio Dayao, P300.00 to kill Douglas, claiming Douglas had poisoned their mother.
- Witnesses reported seeing Jose Bilog interacting with individuals prior to the murder incident on April 19, 1972.
- On the day of the murder, Douglas was seen drinking with Jose and others in his hut.
- During the drinking session, Jose stabbed Douglas with a bladed weapon, and Adriano Canete subsequently joined in the attack.