Title
People vs. Pampolina
Case
G.R. No. 28702
Decision Date
Mar 12, 1928
Two armed men, Julio Abril and Pedro Pampolina, fatally shot Hermogenes Punsalan in 1927. Witness testimony and forensic evidence confirmed their involvement. The Supreme Court upheld their homicide conviction, citing abuse of superior strength but no treachery.

Case Summary (G.R. No. 28702)

Charge and Initial Ruling

The information against the defendants charged them with the crime of homicide for the willful, unlawful, and malicious killing of Hermogenes Punsalan, involving multiple fatal wounds inflicted with revolvers. The trial court found them guilty and sentenced them to fourteen years, eight months, and one day of reclusion temporal alongside a civil indemnification of P500 to the victim's family.

Grounds for Appeal

Only Pedro Pampolina appealed the trial court's decision, alleging various errors including:

  1. The trial court's preference for the prosecution's testimony over his defense.
  2. Incorrectly attributing the empty shells found to him.
  3. Misjudging his involvement in the crime.
  4. Considering his delay in reporting the crime as evidence of guilt.
  5. Failing to give him the benefit of reasonable doubt.

Eyewitness Testimony

On the night of the incident, eyewitness Brigido Refran observed the accused following Punsalan. After a brief conversation, the group split, and moments later, Refran heard gunshots and witnessed both accused firing at Punsalan. Refran affirmed that he saw both Abril and Pampolina with revolvers and described Pampolina's revolver being exposed when he got caught on a wire fence as he fled.

Medical Examination and Evidence

Dr. Manzanero conducted an autopsy on Punsalan the day following the incident and confirmed the presence of multiple fatal wounds consistent with gunshot injuries. Two significant bullets were extracted, matching with a 45 caliber double action revolver, while the empty shells corresponded to a 45 caliber automatic revolver used by Abril, as acknowledged by him during the investigation.

Defense Argument

Pampolina’s defense contended that the mortal wounds were exclusively inflicted by Abril and argued that there was no evidence demonstrating his involvement in the encounter. This argument was undermined by the evidence indicating the presence of multiple firearms and specifically the revolver retrieved from Pampolina during his flight.

Evaluation of Witness Credibility

The trial judge found the testimony of Brigido Refran credible, despite minor inconsistencies that were explained. The court accepted that Refran provided more detailed accounts during the trial, indicating a fear of the accused prior to testifying.

Conclusion on Crime Qualification

The Attorney-General posited that the crime constit

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