Title
People vs. Maghanoy
Case
G.R. No. 67170-72
Decision Date
Dec 15, 1989
Intoxicated constable Herson Maghanoy killed four and wounded one in a violent rampage, claiming self-defense; court convicted him of murder, citing treachery and premeditation.

Case Summary (G.R. No. 67170-72)

Factual Background

On the day of the incident, Maghanoy engaged in a drinking spree, which escalated into violence. After being subdued by Sergeant Carlos Martinez, he and trainee Bartolome retrieved rifles from the PC barracks, returning to the market where they fired into the air. Subsequently, they threatened peace officers and then proceeded to attack civilians, leading to the deaths of Montante, Bartolome, Baguio, and Pacanot. Maghanoy was eventually apprehended after hiding for three days.

Prosecution's Case

The prosecution established a strong case against Maghanoy, citing the credibility and consistency of its witnesses, who detailed the sequence of events surrounding the shootings. The trial court found no motive for these witnesses to falsely accuse Maghanoy, and it noted that the testimony was straightforward and heavily corroborated by physical evidence, including post-mortem findings.

Defense Argument

Maghanoy's defense centered around the assertion that he was innocent and had merely been framed, suggesting that either Bartolome or the pursuing peace officers were responsible for the killings. However, the court found these claims implausible, supported by the forensic evidence that directly linked Maghanoy to the crimes.

Rejection of Defense Claims

The trial court rejected the defense's arguments, highlighting several inconsistencies in Maghanoy's explanations and noting that his defense was fundamentally baseless. For example, the notion that Montante killed Bartolome contradicted medical evidence regarding the wounds on both victims. The defense's failure to produce key evidence, such as the rifle purportedly used by Bartolome, further weakened their position.

Legal Findings

The trial court initially ruled that Maghanoy should face homicide charges for the murders of Montante and Bartolome due to the lack of treachery. However, upon review, it became clear that Maghanoy demonstrated premeditation by arming himself and returning to the public market with clear intent to harm, thereby qualifying the acts as murder.

Penalties and Civil Liabilities

The penalty imposed for each murder was determined to be reclusion perpetua, given the absence of mitigating circumstances. The trial court also consolidated charges related to the complex crime of double mur

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