Title
People vs. Natindim
Case
G.R. No. 201867
Decision Date
Nov 4, 2020
Armed assailants murdered Pepito Gunayan during a home invasion, robbing valuables. Convicted of Murder and Robbery, appellants' penalties were modified to reclusion perpetua and indeterminate prison terms, with damages awarded to the heirs.

Case Summary (G.R. No. 201867)

Procedural History

The accused were charged in two separate Informations: Criminal Case No. 97-1257 for Robbery and Criminal Case No. 97-1258 for Murder. After arraignment most pleaded not guilty except Edimar, Nestor, and Gerry who pleaded guilty. The Regional Trial Court (Branch 25, Cagayan De Oro City) rendered judgment on November 23, 2000 convicting all accused of Murder and Robbery and imposing heavy penalties (including death as then-authorized). The Court of Appeals affirmed with modification on October 14, 2011, and the matter was brought before the Supreme Court, whose decision under review is dated November 4, 2020.

Charged Offenses and Allegations

Robbery (Criminal Case No. 97-1257): accused collectively, with intent to gain and by violence and intimidation while armed, allegedly took movable properties of Judith Gunayan (air gun, radio, goat, two pigs, fighting cock, hen) valued at P7,700.00.
Murder (Criminal Case No. 97-1258): accused allegedly, with evident premeditation, treachery, taking advantage of superior strength and under cover of night, shot and then hacked Pepito A. Gunayan causing mortal wounds that resulted in his death.

Prosecution Evidence and Narrative

The prosecution relied principally on the testimony of Judith Gunayan and corroborating testimony including the NBI medico-legal autopsy and statements of guilty co-accused (Edimar, Nestor, Gerry). Judith recounted that on the evening of July 29, 1997 she and her husband were at home when persons outside identified themselves as local “ronda tanod” and threatened the family. Pepito went to the window and was immediately shot; the assailants then entered, hacked Pepito while he lay dying, hogtied Judith and stole several items. Judith positively identified several accused present at the scene and described specific acts by individuals (e.g., Jimmy taking an FM radio, Rogelio taking a bolo, Gerry tying Judith). Neighbors later freed Judith and found Pepito dead from gunshot and hack wounds.

Defense Case and Accounts by Accused

Several accused provided alibi testimony or denied participation (Arnold, Danny, Johnny, Rolando, Jimmy, Marque, Fernando, Rogelio, Dino). Other accused (Nestor, Gerry, Edimar, Maribel) gave testimony that admitted planning and participation: Nestor and Gerry pleaded guilty and described a meeting in the afternoon to plan Pepito’s killing, the use of “paleontod” firearms, the shooting by Edimar, the subsequent entry and hacking, and seizure of items. Maribel claimed coercion into participation and denied committing the killing. Edimar testified he was paid to kill Pepito and admitted shooting him when Pepito aimed a flashlight and gun.

RTC Findings and Judgment

The trial court found all 15 accused guilty beyond reasonable doubt of Murder in conspiracy, and guilty of Robbery. The RTC credited Judith’s positive and detailed identification; it found treachery, dwelling, nighttime, cruelty, taking advantage of superior strength, aid of armed men, and intoxication as aggravating circumstances, while recognizing spontaneous plea of guilty by some accused as mitigating (but offset by dwelling). The court sentenced most accused to death (then-authorized) for Murder and to reclusion perpetua for Robbery, ordered joint and several civil damages, and provided penalties for minors and others as reflected in the fallo.

Court of Appeals Ruling

The Court of Appeals affirmed the RTC’s convictions for Murder and Robbery for most accused, finding Judith’s positive identifications corroborated by guilty pleas and other evidence. The CA applied R.A. No. 9346 (prohibiting the death penalty) and converted death sentences to reclusion perpetua. The CA remanded the case of Satorane Panggayong for proceedings under R.A. No. 9344 upon report indicating he was a minor at the time of the incident. The CA modified some awards and penalties consistent with statutory changes.

Issues Raised on Appeal to the Supreme Court

Appellants raised multiple contentions, including: insufficiency of the Information for failing to specifically allege qualifying circumstances elevating the killing to murder; erroneous imposition of the death penalty and misappreciation of attendant circumstances; wrongful conviction of particular accused despite alibi or denial; failure to properly consider mitigating circumstances (voluntary plea/surrender/confession); and challenges to the finding of conspiracy and identification.

Supreme Court’s Standard of Review on Credibility and Conspiracy

The Supreme Court accorded deference to the trial court’s assessment of witness credibility, especially where the trial judge observed demeanor firsthand and that finding was affirmed by the Court of Appeals. The Court held that conspiracy may be inferred from the mode and manner of perpetration; explicit prior agreement need not be proved if concerted action and community of purpose are demonstrated by conduct. The Court concluded appellants failed to show that the lower courts overlooked or misapprehended material facts warranting overturning the credibility findings or the conspiracy inference.

Sufficiency of the Information and Qualification to Murder

The Court analyzed the sufficiency requirements under Sections 6 and 9, Rule 110 of the Rules of Court: the Information must state the name of the accused, statutory designation of the offense, acts constituting the offense, name of offended party, approximate time, and place. The Court found that treachery was expressly alleged in the Information for Criminal Case No. 97-1258 because the pleading described shooting Pepito on the head and then hacking him as he fell dying—facts that pled the elements of treachery. Evident premeditation, while referenced, lacked factual averments sufficient to be a pleaded qualifying circumstance and therefore could only be considered as a generic aggravating circumstance. The Court rejected appellants’ reliance on Alba and related arguments because treachery was specifically alleged and adequately apprised the accused.

Application of Treachery and Other Attendant Circumstances

The Court explained treachery’s two elements—victim’s inability to defend and the offender’s conscious adoption of a means or method of attack—were present: Pepito was unarmed and shot while looking out the window, and the subsequent hacking while he lay helpless confirmed the unexpected, sudden nature of the attack. Treachery, once proven and pleaded, qualified the killing to Murder and absorbed certain generic aggravating circumstances (abuse of superior strength, aid of armed men, and nighttime) unless those aggravators were shown to rest on different factual bases; the Court found nighttime was not separately proven to have been purposely sought.

Evident Premeditation, Cruelty, Dwelling, and Intoxication

Although the prosecution proved circumstances indicative of evident premeditation (afternoon meeting to plan, arming, lapse of six hours), the Court treated evident premeditation as a generic aggravating circumstance since the Information did not allege the factual acts necessary to constitute it as a pleaded qualifying circumstance. The Court, applying favorable precedent retroactively, disallowed consideration of cruelty, dwelling, and intoxication as aggravating circumstances because the amended Rules of Court require specific pleading of such attendant circumstances; the judgment was promulgated prior to some relevant doctrine yet the Court gave the favorable rule retroactive effect.

Mitigating Circumstances and Voluntary Surrender/Confession

The Court examined claims that voluntary surrender and plea of guilty should mitigate punishment for certain accused. It held that surrender must be spontaneous, acknowledge guilt, and relate to the crime being prosecuted; the lower courts rightly discounted any claimed surrender as mitigating where it related to other offenses. Voluntary confession of guilt, where present (e.g., Edimar, Nestor, Gerry), was credited as mitigating for robbery sentencing purposes, but the presence of only ordinary mitigating circumstances could not reduce indivisible penalties in murder to a lower degree where the statutory scheme forbids such reduction.

Murder Penalty and Statutory Changes

Under Article 248, treachery qualified the offense as Murder punishable by reclusion temporal to death (or reclusion perpetua to death using older formulations). Given R.A. No. 9346 abolishing the death penalty, the Court affirmed the imposition of reclusion perpetua without eligibility for parole for the convicted appellants whose murder convictions were sustained.

Robbery: Separate Crime versus Robbery with Homicide

The Court clarified that the accused were charged with separate Robbery and Murder, not the complex crime “Robbery with Homicide.” It reiterated the legal distinction: Robbery with Homicide requires that robbery be the main objective and homicide incidental; where the original plan was killing (revenge) and robbery followed incidentally, the proper convictions are Murder and

...continue reading

Analyze Cases Smarter, Faster
Jur helps you analyze cases smarter to comprehend faster, building context before diving into full texts. AI-powered analysis, always verify critical details.