Title
People vs. Cortez
Case
G.R. No. L-13968
Decision Date
Oct 31, 1962
A 1955 wedding dance in Isabela turned violent when a brawl escalated into a fatal stabbing. Librado Pascual died from a chest wound; his ante mortem statement implicated attackers. The Supreme Court ruled it homicide, not murder, due to lack of treachery, and rejected a dubious confession.

Case Summary (G.R. No. L-13968)

Background of the Case

On January 11, 1956, an information for murder was filed against Uy, Pataueg, Sacang, and Cortez in the Court of First Instance of Isabela, due to the fatal incident involving Librado Pascual. The trial concluded with Uy found guilty of murder, sentenced to reclusion perpetua, while his co-defendants faced lesser charges.

Incident Details

The altercation began when Balbino Dulay, acting as the master of ceremonies, attempted to manage the crowd during a special dance. A confrontation escalated when Pataueg physically assaulted a man named Elpidio Pedro, leading to a brawl between the Pascual brothers and the three defendants. Uy and his companions were noted to be armed during the confrontation. The situation deteriorated when Librado Pascual, after being attacked by Pataueg and Sacang, was ultimately stabbed by Uy with a dagger.

Victim's Injuries and Death

After sustaining serious injuries, including a stab wound that penetrated his lung, Librado Pascual was transported to a clinic where he later succumbed to his injuries shortly after 1:20 a.m. on October 25, 1955. Dr. Angel P. Albano documented the injuries and conducted an operation before Librado's passing.

Evidence and Testimony

During the trial, Librado's ante mortem statement identified Sergio Pataueg and Alejo Uy as his attackers. Moreover, Domingo Paual, who testified for the defense, later claimed responsibility for the stabbing, but the court found his testimony unreliable and self-serving. Multiple eyewitness accounts corroborated the prosecution's case against Uy and established a coherent narrative of the events leading to Librado’s death.

Defense and Credibility of Witnesses

Uy contested the credibility of the witnesses, claiming a lack of motive for their testimony against him. However, the court found no substantial justification to doubt the reliability of these witnesses, especially since one of them was related to the deceased, which likely would not induce perjury.

Admissibility of Ante Mortem Statement

The defense also challenged the admissibility of Librado's ante mortem statement. Testimonies from Dr. Albano and Sgt. Ordonez established the circumstances under which the statement was made, indicating Librado's awareness of the impending death due to his severe injuries, thus validating the statement's admissibility.

Legal Evaluation and Rulings

The trial court convicted Uy of murder, classifying the crime as qualifying by treachery. However, upon further examination, it became evident that treachery could not be established as Librado was already engaged in a

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