Title
People vs. Dorico
Case
G.R. No. L-31568
Decision Date
Nov 29, 1973
Three accused attacked Gervacio Dapulag in 1964; Romualdo and Dionisio convicted of murder, Fernando for slight injuries; no conspiracy found.

Case Summary (G.R. No. L-31568)

Material Facts — Eyewitness Testimony

Two principal eyewitnesses for the prosecution testified that on October 12, 1964, at about 5:00 p.m. Rosa Dapulag (the victim’s daughter) saw Romualdo and Dionisio step out of a store and accost her father; one of them stabbed the victim in the upper left arm with the wound exiting near the left armpit; when the victim turned, a second stab to the back and abdomen was inflicted; as the victim tried to flee, Fernando met him and struck him with a fist, causing him to fall, whereupon Romualdo inflicted an additional wound to the knee. Alberto Uy, another eyewitness, testified similarly, placing Romualdo and Dionisio as assailants, hearing prior statements by Honorio Dorico inciting violence, and identifying the weapons as bolos called “Depang.” Two other intended witnesses (Fernando Dones and Purita Becario) left for Manila before trial and were not presented.

Forensic Evidence — Autopsy

The autopsy showed multiple stab wounds: (1) a left mid-lateral arm stab traversing to the axillary/thoracic region (penetrating and fatal), (2) a right dorsolateral thorax stab, (3) a left dorsolateral abdominal stab penetrating to the ventral aspect of the abdomen two inches above the umbilicus, (4) a left knee wound, and (5) a contusion on the right ear. The pathologist concluded there were four stab wounds, two of which were penetrating and fatal (hitting vital organs such as the aortic arch and small intestines), caused by sharp pointed instruments; cause of death was shock from severe hemorrhage due to multiple stab wounds.

Defenses Presented at Trial

  • Romualdo: asserted self-defense, claiming the victim first attacked him with a bolo, they grappled for the weapon, and Romualdo stabbed in repelling the attack; he also claimed he surrendered immediately after the incident.
  • Fernando: pleaded alibi, supported by testimony that he was at the beach earlier on the day in question and returned home upon hearing the news.
  • Dionisio: denied participation (non-participation/bystander position), asserting he was present only as a bystander and implicated due to familial relation.

Trial Court Findings and Original Sentence

The Court of First Instance convicted all three defendants of murder, applying treachery and the aggravating circumstance of superior strength, and sentenced each to death; awarded indemnity (P12,000) and moral damages (P6,000).

Issues on Appeal

The appellants assigned five errors, summarized: (1) the trial court erred in discrediting Fernando’s alibi and in finding prosecution witnesses credible; (2) the trial court erred in rejecting Romualdo’s plea of self-defense; (3) the trial court erred in finding Dionisio participated in the killing; (4) the trial court erred in finding conspiracy among the three accused; and (5) overall error in convicting the appellants as charged.

Court’s Analysis — Alibi (Fernando)

The Court reiterated the settled rule that alibi is a weak defense and must be supported by strong, convincing evidence, particularly when the prosecution presents positive eyewitness identification. The Court found positive identifications of Fernando by eyewitnesses Rosa and Alberto. Testimony offered to support Fernando’s alibi (Agripino Calupo) did not establish that it was physically impossible for Fernando to be at the crime scene because the distance between the beach and the site (about 300 meters) could be traversed in minutes. The Court also noted that the absence of Rosa and Alberto from the preliminary witness list or their not having given sworn statements earlier did not preclude their trial testimony; Section 1, Rule 116 of the Rules of Court allows the prosecution to call witnesses not named in the complaint or information. Consequently, Fernando’s alibi was rejected.

Court’s Analysis — Self-Defense (Romualdo)

The Court set out the elements of self-defense: (1) unlawful aggression, (2) reasonable necessity of the means employed to prevent or repel it, and (3) lack of sufficient provocation by the person defending. The Court found that Romualdo failed to prove self-defense clearly and convincingly. The autopsy wounds and their locations (notably penetrating stabs from behind/side to the chest and abdomen) indicated blows inflicted when the victim’s back or side was exposed, inconsistent with a forward thrust during a direct mutual grapple for a weapon. The nature and direction of the fatal stab wounds suggested they were not the result of an immediate defensive thrust in close mutual combat. Further, Romualdo’s conduct in discarding the weapon after the stabbing and the lack of sustaining defensive injuries weakened his self-defense claim. The Court emphasized the requirement that one asserting self-defense must rely on the strength of his own evidence rather than on the prosecution’s weaknesses. Romualdo’s proof was insufficient, so the plea of self-defense failed.

Court’s Analysis — Participation (Dionisio)

Dionisio’s denial of participation was weighed against direct eyewitness testimony identifying him as one of the assailants. The Court upheld the trial court’s credibility determinations, noting that trial courts have superior opportunity to assess witness credibility. The absence of an established motive for Dionisio was not dispositive: motive is relevant primarily when identity is in doubt. Given credible positive identifications by witnesses, the Court found participation proven beyond reasonable doubt.

Court’s Analysis — Conspiracy

The Court examined whether there was proof of a prior conspiracy requiring unity of purpose and unity in execution. Evidence showed Romualdo and Dionisio (and Honorio Dorico) were together before the attack and that Honorio voiced an inciting statement immediately before the assault. The Court concluded, however, that joint or simultaneous action alone does not establish conspiracy; there must be proof of prior concert as clearly and convincingly as the commission of the offense itself. The circumstances better support

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