Title
People vs. Givera y Garote
Case
G.R. No. 132159
Decision Date
Jan 18, 2001
Cesar Givera convicted of murder for 1993 stabbing of Eusebio Gardon; conspiracy, abuse of superior strength proven; damages modified.

Case Summary (G.R. No. L-30085-87)

Core Factual Narrative Established at Trial

Eyewitness testimony (chiefly from the victim’s daughter Milagros Gardon and niece Melinda Delfin) described a coordinated assault: the assailants stoned the victim’s house to force him out; Epifanio entered the house and led the intoxicated victim outside; Cesar reportedly hurled stones and boxed/kicked the victim while two others lay in wait; the group lured the victim toward a bridge where Maximo stabbed him, resulting in a fatal wound. The witnesses identified four assailants present at the stabbing scene.

Prosecution Evidence

Primary evidence consisted of two eyewitness accounts (Milagros Gardon and Melinda Delfin) who observed the events and identified Cesar as among the aggressors. The prosecution also offered a medico-legal officer’s testimony (from the separate case) describing a single fatal stab wound penetrating the pericardium and left ventricle, and a death certificate. The medico-legal testimony was, however, taken in the co-defendants’ case and the prosecution did not produce the medico-legal witness for cross-examination in Cesar’s trial.

Defense Evidence and Position

Accused-appellant Cesar testified in his own defense, denying participation in the fatal stabbing. He claimed to have been drinking at a cousin’s home some thirty meters away, to have tried to pacify a quarrel between Maximo and the victim, and to have led the victim to his home. He asserted that after the victim engaged again in a fight, he attempted to help but fled when the victim’s son allegedly came with a bolo; he denied seeing a stabbing and claimed he learned of the victim’s death only later. Cesar contended his presence only at the scene did not make him responsible for the homicide.

Trial Court Judgment

The trial court found Cesar guilty beyond reasonable doubt of murder and sentenced him to reclusion perpetua with accessory penalties, ordered indemnity to the heirs in the amount of P50,000.00, and imposed costs. Cesar appealed, contesting the sufficiency of evidence and raising ancillary procedural and evidentiary objections.

Issue on Appeal

The principal assignment of error was that the conviction was supported by reasonable doubt. Additional issues addressed on appeal included the existence and validity of the arrest warrant and the admissibility of the medico-legal testimony taken in the separate case.

Credibility and Sufficiency: Supreme Court Findings

The appellate tribunal affirmed the trial court’s credibility assessments. It found the eyewitnesses’ accounts spontaneous, detailed, and consistent on the essential facts: that Cesar and his companions were the last seen with the victim and that they participated in stoning, beating, and ultimately in the assault culminating in the fatal stabbing. Minor inconsistencies in peripheral details were deemed immaterial and not undermining the witnesses’ core testimonies. The Court also noted absence of demonstrated ill motive on the part of the witnesses that could explain fabrication.

Conspiracy and Imputation of Liability

The Court concluded that a common design or conspiracy existed. The facts—stoning the house to draw the victim out, one defendant entering to escort the victim, the pursuit to lure him toward a location where others awaited, and the collaborative physical assault—demonstrated a coordinated plan. Applying the principle that acts performed in furtherance of a common purpose are attributable to all conspirators, the Court held Cesar criminally liable for murder as if he had personally inflicted the fatal blow.

Evident Premeditation: Court’s Analysis

The Court declined to recognize evident premeditation as a qualifying circumstance. It distinguished between express (direct) conspiracy, where premeditation can be proven by showing deliberation and prior selection of means and time, and the implied or constructive conspiracy here. The prosecution did not show how or when any plan to kill was formed nor the lapse of time allowing for cool reflection; therefore, evident premeditation could not be appreciated.

Treachery: Court’s Rationale

Treachery was also rejected as a qualifying circumstance. Treachery requires deliberate, unexpected attack at the inception such that the victim has no opportunity to defend. The Court observed the victim had received warnings and was not completely oblivious; he followed two assailants and thus had some awareness and ability to anticipate danger. Any surprise at the moment of seeing additional attackers did not suffice to establish treachery as legally required.

Abuse of Superior Strength: Qualifying Circumstance Found

The Court affirmed the presence of abuse of superior strength as a qualifying circumstance. The evidence established the victim was unarmed, outnumbered, and confronted by four assailants—one armed with a knife—thereby demonstrating a clear numerical and physical superiority exploited in the assault.

Warrant of Arrest and Waiver of Objections

The Court addressed Cesar’s contention that his arrest was without a warrant. Records showed a warrant of arrest issued on April 27, 1995; although returned unserved when Cesar could not be located and later executed when Cesar was found on May 4, 1996, no alias warrant was required. Further, Cesar did not file a motion to quash prior to pleading; by pleading not guilty and participating in trial, he was deemed to have waived objections going to the court’s jurisdiction over his person. The Court applied the doctrine that procedural objections to the acquisi

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