Title
People vs. Panes
Case
G.R. No. 116744-47
Decision Date
Aug 29, 1997
Four Cocjin family members were killed in 1987 by armed assailants, including soldiers. The Supreme Court upheld murder convictions, rejecting self-defense claims due to treachery and lack of evidence.

Case Summary (G.R. No. 116744-47)

Nature of the Charges

The accusations stem from four separate informations for murder filed against the appellants, which were processed by the Regional Trial Court, 11th Judicial Region, Branch 26 in Surallah, South Cotabato on September 30, 1987. The charges detail conspiring to commit murder against the Cocjin family, employing treachery, evident premeditation, and taking advantage of their superior strength as armed military personnel.

Events Leading to the Murders

Eyewitness testimony from Demetrio Paypon, Jr. served as the cornerstone of the prosecution's case. He described an incident on the aforementioned date where the Cocjin family was ambushed while standing near a fence. Paypon witnessed Toldo Panes signaling an attack, which prompted Manuel Panes, Noel Dela Cruz, and Wilson Velasco to engage in lethal actions against the Cocjins, armed with military-grade firearms.

Victim Testimonies and Autopsies

Post-mortem examinations were carried out by Dr. Vincent Dave Farhat, revealing that Juanillo Cocjin, Sr. sustained seven bullet wounds, indicating the severity of the assault. Other victims also bore multiple gunshot wounds, solidifying the notion of a calculated and ruthless approach to the attacks by the appellants.

Defense and Allegations

The defense claimed self-defense, asserting that the Cocjins had initiated the conflict by attacking with bolos. However, this assertion lacked corroborative evidence, such as the recovery of any weapons from the scene, and was directly contradicted by eyewitness accounts. The appellants claimed they were responding to an armed threat, yet the court found no substantiation to their defense and ruled it inconsistent with the testimonies and evidence presented.

Court's Assessment of Self-Defense and Conspiracy

The trial court identified that self-defense necessitates clear evidence of unlawful aggression, which was absent, as the Cocjins were unarmed and taken by surprise. Additionally, the ruling found that the appellants acted in consort, suggesting a deliberate agreement to execute the murders rather than a mere response to an attack. This calculated plan further solidified the court’s evaluation of treachery, as they employed superior arm

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