Case Summary (G.R. No. 75369)
Background and Charges
On August 4, 1980, an information was filed for murder against Fernando Iligan, Edmundo Asis, and Juan Macandog. The crime involved the fatal hacking of Esmeraldo Quinones, Jr., who sustained injuries on his face and head inflicted by Fernando Iligan using a bolo (sinampalok). Juan Macandog was not apprehended and remained at large. At the arraignment held on January 12, 1981, Fernando Iligan and Edmundo Asis pleaded not guilty.
Account of Events According to the Prosecution
At around 2:00 a.m. on the date of the incident, the victim and his companions were walking home from a barrio fiesta dance when they encountered the accused. Edmundo Asis allegedly pushed the victim’s group aside, leading to a brief altercation where Zaldy Asis boxed Edmundo. Fernando Iligan then brandished a bolo and attempted to hack Zaldy Asis but missed. The victim and his companions fled and after resting, were invited by Quinones to go to his house. While approaching the house, Fernando Iligan suddenly attacked and hacked Esmeraldo Quinones, Jr. on the forehead, causing him to fall. The companions fled but returned upon hearing shouts, finding the victim dead with a busted head.
Medical Evidence and Cause of Death
Dr. Marcelito E. Abas performed an autopsy and reported multiple fractures and massive cerebral hemorrhages in half of the victim's skull, accompanied by several wounds including an incised wound on the right eyebrow and abrasions on the shoulder and neck. The death certificate stated the cause of death as “shock and massive cerebral hemorrhages due to a vehicular accident,” which was disputed by the prosecution and the victim’s father, Esmeraldo Quinones, Sr., who stated from counsel he received that if a hacking and vehicular incident had occurred simultaneously, the hacking wound would not be visibly evident.
Defense and Alibi
The accused denied involvement. Fernando Iligan testified that he was picking up visitors from the dance hall and later met Edmundo Asis, who was presumed drunk. They were boxed by an unknown person raising a scuffle, after which they returned home accompanied by a companion, Juliano Mendoza. Edmundo Asis corroborated this testimony and stated he was at home sleeping during the alleged time of the crime.
Trial Court’s Findings
The trial court rejected the vehicular accident theory, finding no conclusive evidence of such based on photographs and testimonies. The court held that Iligan’s group had conspired to kill as retaliation for the earlier boxing incident and found evident premeditation and treachery. Consequently, the court convicted Fernando Iligan and Edmundo Asis of murder, sentencing them to reclusion perpetua and ordering indemnification for the victim’s heirs.
Appellate Court Review and Analysis of Evidence
The appellate court thoroughly reviewed the evidence, including the defense’s reliance on Dr. Abas’s testimony that the victim’s head fractures were caused by a vehicular accident, supported by claims of tire marks on the victim’s shoulder and neck. Eyewitnesses recounted hearing shouts suggestive of a vehicular accident shortly after the bolo attack. Barangay captain Marciano Mago testified to seeing tire marks and scattered brain matter at the crime scene.
Despite evidence that the fatal head injury was caused by a vehicle, the court held that Fernando Iligan’s hacking was the proximate cause leading to the victim’s death. Under Article 4 of the Revised Penal Code, a person is criminally liable for any direct, natural, and probable consequence of an intentional felony, even if the resulting act differs from the intended one. The act of hacking the victim was intentionally directed at a vital part — the head — with the intent to kill, resulting in the victim falling onto the roadway where he was run over by a vehicle. This chain of causation established Iligan’s legal responsibility for the death.
Dismissal of Aggravating Circumstances on Appeal
The appellate court disagreed with the trial court’s appreciation of treachery and evident premeditation. The element of treachery requires that the mode of attack make it difficult or impossible for the victim to defend himself consciously, which was not proven merely by the suddenness of the attack. The prior hostile acts were deemed warnings, allowing the victim’s group to anticipate a possible attack. Moreover, the requisites for evident premeditation — determination to commit the crime, an overt act indicating such intention, and lapse of time for reflection — were not sufficiently established.
Exoneration of Edmundo Asis
Evidence did not prove Edmundo’s active participation in the assault or conspiracy. Mere presence and knowledge of Fernando’s criminal intent without active cooperation did not make Edmundo a co-conspirator, co-principal, or accomplice. The testimony implicating Edmundo lacked corroboration and came from a biased witness. Hence, Edmundo Asis was acquitted.
Final Holding and Penalty Imposed
Fernando Iligan was convicted of homicide, with the penalty adjusted accordingly to reclusion temporal medium, applying the
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Case Syllabus (G.R. No. 75369)
Facts of the Case
- On October 21, 1980, an information for murder was filed against defendants Fernando Iligan, Edmundo Asis, and Juan Macandog for the killing of Esmeraldo Quinones, Jr. at Sitio Lico II, Barangay Sto. Domingo, Vinzons, Camarines Norte.
- It was alleged that Fernando Iligan, armed with a bolo, hacked Quinones on the face with treachery and evident premeditation, which caused fatal injuries resulting in Quinones’ death.
- Juan Macandog was never apprehended and remained at large.
- On August 4, 1980, around 2:00 a.m., Quinones and his companions Zaldy Asis and Felix Lukban were returning home from a barrio fiesta dance when they encountered the accused. A confrontation ensued wherein Edmundo Asis pushed the group of Quinones, causing Zaldy Asis to box Edmundo.
- Fernando Iligan then drew a bolo and hacked Zaldy Asis, who escaped along with the others, pursued briefly by the accused.
- As Quinones and his companions rested and proceeded to Quinones’ home, the accused suddenly attacked; Fernando Iligan hacked Quinones on the forehead, causing him to fall seriously injured.
- Witnesses heard shouts indicating someone was caught, and when Zaldy and Felix returned, they found Quinones dead with a severe head injury.
- An autopsy conducted the same day revealed massive cerebral hemorrhages and multiple fractures in the left half of Quinones’ head, along with incised wounds and abrasions on his body.
- The death certificate initially indicated death due to shock and massive cerebral hemorrhages caused by a vehicular accident.
- The accused denied involvement, each giving alibi testimonies and claiming to have been in their homes at the time of the incident.
Trial Court Findings and Conviction
- The Court of First Instance of Camarines Norte convicted Fernando Iligan and Edmundo Asis of murder, sentencing them to reclusion perpetua and ordering indemnity payments to the heirs of Quinones.
- The court found that Iligan’s group conspired to kill Quinones or his companions to avenge the boxing of Edmundo Asis.
- Aggravating circumstances of treachery and evident premeditation were appreciated.
- The court discredited the defense’s claim of vehicular accident as the cause of death due to lack of evidence and contradictions in the death certificate and photographic evidence.
- The testimony of the victim's father about seeing Iligan armed with a bolo chasing the victim influenced the court’s findings.
Prosecution’s Evidence and Version of Events
- Testimonies of witnesses Zaldy Asis and Felix Lukban detailed the encounter, initial aggression by the accused, the pursuit, and eventual fatal attack on Quinones.
- The victim suffered massive injuries consistent with hacking by a sharp instrument.
- The prosecution relied on the testimonies and forensic autopsy report to establish direct cause of death.
- The victim’s father corroborated