G.R. No. L-30449 - People vs. Garcia y Cabarse

Case Summary (G.R. No. L-30449)

Background and Incident

The appeal originated from a decision dated April 17, 1969, by the Circuit Criminal Court in Pasig, Rizal, which found Garcia and Arviso guilty of murder and sentenced them to death. The case arose from an incident that occurred on October 19, 1968, during which Corazon Dioquino Paterno, the sister of the deceased, Apolonio Dioquino Jr., witnessed a chase involving multiple assailants, including the two defendants, against her brother.

Eyewitness Testimony

Corazon testified that she had moved to Pasay City and had seen her brother, Apolonio, fleeing from a group of men. She recognized Garcia and Arviso, who had been former associates of her brother. During the incident, she witnessed Garcia attacking her brother with a long knife while the group physically assaulted him. Corazon reported the incident to the police and later identified the defendants in custody.

Autopsy Findings

The prosecution presented Dr. Mariano Cueva Jr., who conducted the autopsy on Apolonio’s body, revealing he sustained 22 stab wounds. The forensic evidence substantiated that these injuries caused massive hemorrhaging leading to death.

Defendants' Alibi

In their defense, both Garcia and Arviso claimed to have alibis. Garcia stated that he was at a canteen nearby during the incident, while Arviso claimed he was at home after a night of drinking. However, the trial court dismissed their alibis as unpersuasive, given their proximity to the crime scene.

Trial Court's Findings

The trial court primarily relied on Corazon’s testimony as a credible account of the events. It determined that the defendants' actions constituted murder, noting the aggravating circumstances of nighttime, superior strength, and treachery. The court concluded that the evidence overwhelmingly implicated the defendants in the commission of the crime.

Defendants' Appeal Arguments

On appeal, the defendants contended that the trial court erred in considering nighttime and superior strength as aggravating circumstances and in determining that treachery was present without sufficient evidence. They argued that their guilt had to be discredited based on inconsistencies in Corazon's testimony and the absence of evidence against Arviso in the commission of the murder.

Analysis of Corazon's Testimony

The appellate court assessed the validity of the defense’s attempts to undermine Corazon’s credibility, focusing on alleged inconsistencies about the distances involved and the timing of her actions. Despite the defense's arguments, the appellate court acknowledged the emotional distress experienced by Corazon as she witnessed her brother's murder, stating that her testimony should not be expected to endure rigorously detailed scrutiny.

Conspiracy and Guilt

The appellate court addressed the contention concerning Arviso’s involvement, stating that participation in the murder could be inferred from the concerted actions of both defendants in pursuing Apolonio. It established that even without direct evidence of his involvement in the actual killing, Arviso's role in the conspiracy was sufficient for his guilt.

Legal Findings on Qualifying Circumstances

The appellate review found flaws in the trial court’s identification of treachery as a qualifying circumstance. It concluded that while the crime involved elements of abuse of superiority, it could not be stric