Title
People vs. Guarnes
Case
G.R. No. L-12819
Decision Date
Dec 29, 1960
A 1956 serenade turned deadly as Eustiquio Jabonillo was fatally stabbed and beaten by Isidro, Monico, and Honorio Guarnes. The Supreme Court convicted all three, rejecting self-defense claims and affirming treachery and conspiracy.
treachery
conspiracy
murder

Case Summary (G.R. No. L-12819)

Factual Background of the Assault

On June 6, 1956, at about 7:00 p.m., Eustiquio Jabonillo and several companions—Remigio Gumban, Rufo Latosa, Alfonso Hisog, Dionisio Guro, and Mariano Cabillos—left the public market of Pavia and went to serenade at the house of Jovita Jaurequi, located about 12 meters from the railway tracks. At about 8:00 p.m., the group walked home in single file toward the railway tracks, with Eustiquio at the tail and strumming a ukelele.

As Remigio Gumban and the others crossed the railway tracks, Remigio heard a noise from an object brushing aside shrubs. When he turned, he saw Isidro Guarnes stab Eustiquio on the chest, prompting Eustiquio to exclaim “Abaw.” After Eustiquio staggered, Monico Guarnes, armed with a galvanized iron pipe, and Honorio Guarnes, armed with a “bahi” (cane), struck Eustiquio on the back, after which Eustiquio fell to the ground face down. These brothers were first degree cousins of Isidro.

Witness Mariano Cabillos, who also saw the assault, attempted to help his companion, but Isidro—armed with an Indian target (sling shot)—warned him not to approach. Cabillos, Gumban, and Hisog then ran to the municipal building and reported the incident. Cabillos also notified Eustiquio’s brother, who in turn informed policeman Gregorio Jabonillo.

Police Investigation and Medical Findings

Cabillos informed policeman Eliseo Granfillo that the deceased was stabbed by Isidro and that Monico and Honorio had ganged up on Eustiquio. Granfillo and Cabillos proceeded to the scene and found the victim lying face downwards. Upon turning over the body, they found a butcher’s knife (Exhibit B) on the ground near where he lay.

Dr. Jose Acosta, the municipal health officer of Pavia, conducted a post mortem examination. He found that Eustiquio sustained a stab wound on the left chest just above the nipple, and two contusions on his back. The medical findings indicated that these injuries caused death in a matter of seconds (Exhibit A).

Evidence Presented for the Appellants

Isidro Guarnes presented a version of events that purportedly showed self-defense. He testified that before 7:30 p.m. on June 6, 1956, he went to the house of Jovita Jaurequi where he used to pass the night, to accompany her family because her deceased husband was his cousin. He claimed that from about 30 meters away he heard strumming of a guitar, and when he was about 6 meters from the house, he saw a person under Jovita’s house peeping. When the person reached for a chicken, Isidro called him twice but did not receive an answer. Isidro said he then picked up a piece of wood and struck the person on the back. He claimed that the would-be chicken thief ran away but that he pursued and struck him again with the piece of wood.

Isidro claimed that the unknown person faced him and appeared to draw something from his hip pocket. He testified that he recognized the person as Eustiquio Jabonillo, whom he knew to be of a dangerous disposition. He then said he became afraid, drew his butcher’s knife, and grappled with Eustiquio for the possession of the knife. Isidro claimed that during the struggle he was able to kick one leg of Eustiquio, causing Eustiquio to fall to the ground with Isidro on top. Isidro testified that he ran away when he noticed Eustiquio was wounded. He also admitted that he did not surrender that evening due to lack of transportation but surrendered early the following morning, June 7, 1956, and stated that no one helped him during the struggle.

Monico Guarnes denied involvement. He testified that after gathering tuba at about 7:30 p.m., he stayed home and did not go out. He claimed he had visitors, namely Pablo Jauco and Julio Latosa, who drank tuba with him. He also said that Aida Gulac went to get back her pliers. He testified that he heard shouts and that he saw policeman Gregorio Jabonillo walking back and forth near the body of Eustiquio, and that he wanted to go down but was prevented by his wife.

The defense presented additional circumstances intended to negate Monico’s participation: it was shown that Cabillos, investigated that same night, implicated only Isidro, not the co-accused; that Monico had nine children; that he did not keep any iron pipe in his house; that he had no altercation, ill feeling, or grudge against Eustiquio; and that he was a peaceful, law-abiding citizen.

Honorio Guarnes likewise relied on denial and alibi. He stated that he was watching fifty hens and cocks when the incident occurred and that he was suffering from an intestinal illness requiring rest upon the advice of Dr. Acosta. He claimed he had no altercation or quarrel with Eustiquio and that he did not meet Isidro or Monico that night. It was also shown that Honorio was a midget, about four feet and two inches tall, which the defense treated as inconsistent with his alleged ability to attack with the cane.

The Court’s Evaluation of the Witnesses’ Credibility and Identification

The Court held that there was no doubt that the killing occurred in the manner described by the prosecution witnesses. It relied on the testimony of three eye-witnesses who identified and saw the assault. Gumban testified that after he had crossed the railway tracks, he heard noise caused by an object brushing against shrubs, turned, and saw Isidro stab Eustiquio on the chest, after which Monico struck the victim with the iron pipe and Honorio struck him with the cane until he fell. Hisog corroborated the same account. Cabillos corroborated Gumban’s testimony.

The Court found that these witnesses knew whereof they spoke because they were companions of the deceased before, during, and after the serenade and were the ones who reported the incident to the authorities. It further noted that, when Cabillos was investigated that night by Pat. Granfillo, he stated that the deceased was stabbed by Isidro and ganged up on by Monico and Honorio. The Court rejected the appellants’ theory that the witnesses committed self-contradictions and exaggerations, concluding that the alleged inconsistencies referred only to inconsequential and minor details. It also found no motive for the witnesses to falsely implicate Honorio and Monico.

On the contrary, the Court concluded that the trial court had properly credited the witnesses’ testimony and that the record supported that evaluation. It likewise held that the identification was sufficiently clear despite the night conditions because the light from the wick lamp on the window of Jovita’s house reached the place of the incident, which was only about twelve meters away.

Rejection of Self-Defense, Denials, and Alibi

The Court held that Isidro’s claim of self-defense was not substantiated. It characterized Isidro’s story as unbelievable and even fantastic. It also echoed the Solicitor General’s observation that the accused’s version suggested a tenacious chicken thief who, despite being accosted multiple times, did not flee until hit, and that the story lacked candor because Isidro did not state the obvious fact that he plunged his knife into the deceased. The Court held that the positive testimony of three witnesses—unshown to have improper motives—overcame Isidro’s attempt to rely on his version.

The Court applied similar reasoning to Monico’s and Honorio’s denials and alibi. It found that the prosecution witnesses testified in a positive, direct, and straightforward manner that Monico and Honorio ganged up on Eustiquio, which explained the two injuries on the victim’s back produced by the cane and iron tube. It held that Honorio’s physical condition was not a bar to his alleged participation because the record did not indicate any incapacity preventing him from wielding the cane and striking the victim.

The Court also observed that the defense’s alleged locations for Monico and Honorio were near the scene of the crime, making it not impossible for them to have been present at the time of the incident. It therefore found the defense explanations insufficient to generate reasonable doubt.

Conspiracy, Treachery, and the Manner of Attack

The Court found that treachery (alevosia) and conspiracy attended the killing. It reasoned that the attack was sudden and unexpected. It emphasized that Eustiquio could utter only “Abaw” immediately after Isidro stabbed him without warning. The Court further found that Monico and Honorio’s appearance and attack were also sudden, and that the witnesses did not know where they came from before they attacked. It treated the near-simultaneous action and the coordinated positioning—Isidro attacking first and the brothers appearing ready to strike, even in anticipation of interference—sufficient to show concerted action, citing People vs. Tamayo, 44 Phil. 38.

The Court also addressed aggravation. It acknowledged that abuse of superior strength would otherwise qualify as an aggravating circumstance. However, it held that this aggravating circumstance was absorbed by the qualifying circumstance of treachery, citing People vs. Balines, et al., G.R. No. L-9045, Sept. 28, 1956.

Motive and Participation of the Accused

The Court found that prior circumstances supplied motive. It held that Isidro had been heard making a threat that the deceased was number one in his list and that he had earlier altercations with the deceased, dated back to 1951. It also found that Isidro resented the serenade held at the house of Jovita, identified as the widow of his first cousin, Manuel Guarnes. It viewed Monico and Honorio as drawn into the assault by their natural de

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