G.R. No. 109991 - Quibal vs. Sandiganbayan

Case Summary (G.R. No. 109991)

Petitioner and Respondent

Petitioner: People of the Philippines (plaintiff-appellee). Respondents/Accused-appellants: Ronnie Quitlong, Salvador Quitlong, and Emilio Senoto, Jr. (with Jesus Mendoza and others named in the amended information but Mendoza at large).

Key Dates and Procedural History

Information for murder filed 25 October 1994; amended information adding Jesus Mendoza filed 12 December 1994 after reinvestigation; victim died 20 October 1994 (8:55 p.m.); trial court rendered judgment (convictions and sentences) on 21 April 1995; the Supreme Court decision under review was rendered July 10, 1998. Because the decision date is 1998, the analysis applies the 1987 Philippine Constitution.

Applicable Law and Procedural Rules

1987 Constitution, Article III, Section 14 — due process and right to be informed of nature and cause of accusation.
Rules on Criminal Procedure and Rules of Court provisions cited: Sections of Rule 110, Rule 111, Rule 115 and related criminal procedure rules governing the contents of an information and amendments.
Revised Penal Code provisions invoked: Article 17 (principals), Article 18 (accomplices), Article 248 (murder qualified by abuse of superiority), and sentencing principles including the Indeterminate Sentence Law. Jurisprudence on conspiracy pleading and reclusion perpetua (People v. Lucas and other authorities) also considered.

Facts of the Offense

On the evening of 20 October 1994, after a dispute with a fishball vendor, victim Calpito and companions were confronted near Harrison Road, Baguio City. A group of men arrived from the taxi-stand area and cornered Calpito. Eyewitness Adjaro observed appellants Emilio holding the victim from behind, Salvador holding the victim’s right hand, and Ronnie holding the left hand. Adjaro saw Ronnie stab Calpito on the left chest; Calpito was carried to a jeep, taken to Baguio General Hospital, and died at 8:55 p.m. Autopsy by Dr. Ayro revealed a single stab wound penetrating the pericardium and apex of the left ventricle, causing hypovolemic shock.

Evidence Collected and Key Witnesses

Eyewitness testimony: Lito Adjaro identified Ronnie as the stabber and described the roles of Salvador and Emilio in restraining Calpito. Herbert Soriano corroborated the crowd and the transport of the wounded victim. Other vendors (Nonita de los Reyes, Lydia Cultura) provided testimony attributing the stabbing to Jesus Mendoza.
Physical evidence: a stainless knife with bloodstains (Exhibit B) recovered near the scene, identified by Adjaro as the weapon used.
Medical evidence: autopsy report establishing cause of death and wound characteristics.
Documentary/process evidence: police reports and crime reporting forms indicating arrests of appellants and Mendoza’s escape.

Defense Theory and Amended Information

Following the filing of the original information, the accused sought reinvestigation contending Jesus Mendoza was the stabber. Affidavits by several vendors and the Quitlongs themselves led the prosecution to file an amended information naming Mendoza. Mendoza remained at large. At trial, the defense admitted the appellants’ presence at the scene but denied participation in the stabbing; several vendor witnesses claimed Mendoza committed the stab.

Trial Court Findings and Sentencing

The trial court found the three accused guilty of murder as charged, concluding that conspiracy among members of the group could be inferred from the information’s averment of abuse of superior strength and combined action. It sentenced each accused to an indeterminate term (20 to 40 years) of reclusion temporal/reclusion perpetua range, imposed civil indemnity and damages, declared the knife forfeited, and directed transfer to the Bureau of Corrections. The trial court’s ruling treated Ronnie as principal and the other two as co-principals under a conspiracy theory.

Issues Raised on Appeal

Appellants challenged (a) the trial court’s finding of conspiracy despite the information’s failure to explicitly allege conspiracy; (b) the attendant imputation of co-principal liability without a properly pleaded conspiracy; and (c) the characterization of the crime as murder rather than homicide (challenging qualifying circumstances and degree of liability).

Legal Analysis — Pleading Conspiracy and Constitutional Due Process

The Supreme Court emphasized that under the 1987 Constitution (Article III, Section 14) and criminal procedure rules, an accused must be informed of the nature and cause of the accusation to prepare an adequate defense. An information must include facts essential to the accused’s culpability, and when criminal liability is to be based on the acts of others (as in conspiracy), the information must allege conspiracy or facts that unmistakably convey a common design or unity of purpose. Conspiracy is not an ordinary recitable fact that can be supplied later by evidence; it is an allegation that, if it will support imputation of another’s acts to an accused, must appear in the charging document so the accused can meaningfully plead and defend. The Court rejected the trial court’s view that conspiracy could be inferred merely from language describing abuse of superior strength or collective action, holding that the information did not sufficiently allege a confederation or community of design among the accused.

Court’s Assessment of Witness Credibility and Individual Liability

Although the indictment failed to properly allege conspiracy, the Supreme Court deferred to the trial court’s credibility determinations concerning eyewitness Adjaro. Adjaro’s testimony was consistent, categorical, and corroborated by Soriano and police observations. The Court accepted the trial court’s finding that Ronnie was the actual stabber based on positive identification at trial. Given that finding, Ronnie was held liable as principal by his own act (Article 17), while Salvador and Emilio—who were shown to have held and restrained the victim at the time—were not proven to have shared a prior conspiracy and therefore could not be treated as co-principals under a conspiracy theory.

Application of Penal Code Provisions: Principals, Accomplices and Aggravating Circumstances

Ronnie Quitlong: convicted as principal by direct act of stabbing. The fact of a solitary stab wound causing death supports the homicide/murder finding; the crime was qualified by abuse of superiority (Article 248), given combined strength and disparity of means of defense. Treachery was not proved as an aggravating circumstance.
Salvador Quitlong and Emilio Senoto, Jr.: held as accomplices (Article 18) because they cooperated by previous or simultaneous acts of holding the victim rather than as co-principals by conspiracy. Simultaneity of acts did not itself prove concurrence of will or prior agreement required for conspiracy.

Sentencing Principles and Indeterminate Sentence Law Application

The Court applied sentencing rules consistent with jurisprudence on reclusion perpetua and the Indeterminate Sentence Law. It noted the Supreme Court’s prior cl

Case Syllabus (G.R. No. 109991)

Procedural Posture and Case Background

The case appears as reported at 354 Phil. 372, First Division, G.R. No. 121562, decided July 10, 1998, with Justice Vitug penning the Decision.
The criminal action arose from Criminal Case No. 13336-R before the Regional Trial Court (RTC) of Baguio City, Branch 5 (presided by Judge Salvador J. Valdez, Jr.).
An information for murder was filed on October 25, 1994, charging Salvador Quitlong, Ronnie Quitlong, Emilio Senoto, Jr., and several unidentified persons with the killing of Jonathan Calpito.
Accused-appellants filed a motion for reinvestigation shortly after the filing of the information, alleging that a certain Jesus Mendoza stabbed the victim. The trial court granted the motion for reinvestigation.
On December 12, 1994, the City Prosecutor moved to admit an amended information (supported by affidavits, including those of Salvador and Ronnie Quitlong) that added Jesus Mendoza among the named accused; Mendoza, however, remained at large.
The detained accused were arraigned and pleaded not guilty. The trial court rendered its decision on April 21, 1995; the case was appealed to the Supreme Court and decided July 10, 1998.

Facts of the Case (Chronology of Events)

On the evening of October 20, 1994, at around 6:00 p.m., Jonathan Calpito (19, a University of Baguio medical technology student) was playing billiards with Jonathan Gosil; Lito Adjaro (a neighbor and barkada) joined them later.
At past 8:00 p.m. the three friends walked toward Harrison Road to get a taxi. The area was well-lighted.
Calpito and Gosil bought fishballs; a dispute arose because Calpito allegedly received incorrect change (he believed he was short-changed, receiving only P35 from a P100 bill).
While arguing with the fishball vendor, Herbert Soriano (a civil engineer driving a jeepney) was hailed; he parked about four to five meters from the scene.
From the direction of the taxicab stand, eight men rushed toward Gosil and Calpito. Some men backed out but four pursued Calpito. Calpito retreated, was cornered, and fell to the ground; when carried to Soriano’s jeep, Soriano realized Calpito had been stabbed.
Adjaro saw about eight men confront Calpito and Gosil. He then boarded Soriano’s jeep and observed the attack.
Adjaro and Soriano described seeing Emilio Senoto embrace Calpito from behind; Salvador Quitlong and Ronnie Quitlong holding Calpito’s right and left hands, respectively; Calpito struggled to free himself.
Ronnie Quitlong allegedly stabbed Calpito at the left side of the body just below the nipple; after being released, Calpito fell and was kicked by his assailants despite already being wounded.
Police officers on patrol responded; some attackers fled while others continued the assault. Officers detained some assailants at the scene and took them to the police station.
Calpito was taken to Baguio General Hospital but died the same evening at 8:55 p.m.

Investigation, Arrests and Physical Evidence

Police officers Jerry Patacsil, Arthur Viado, and Nito Revivis observed Calpito lying on the ground with bloodstains; they advised companions to rush him to the hospital.
The police brought accused-appellants to the police station; SPO1 Gabriel Isican prepared the complaint assignment sheet.
SPO4 Avelino Tolean and SPO1 Rafael Ortencio, Jr. went to the hospital, interviewed witnesses (Adjaro and Gosil), then inspected the crime scene.
A stainless knife with bloodstains (exhibit identified in the record as Exhibit B) was recovered near flowering plants beside an electric post; Adjaro recognized it as the knife used to stab Calpito.
SPO4 Gerardo Tumbaga prepared Form 1 of the National Crime Reporting System stating the accused were arrested and that a certain Mendoza escaped; the report indicated Adjaro and Gosil had earlier been drinking with Calpito at the Genesis Folkden.

Medical and Forensic Findings

Dr. Kathryna Ayro, medico-legal officer of Baguio General Hospital, conducted the autopsy at the request of the attending surgeon Dr. Samuel Cosme and First Assistant City Prosecutor Herminio Carbonell, with consent of a brother of the deceased.
Autopsy findings disclosed a solitary stab wound penetrating the left thoracic cavity at the level of the 5th intercostal space, producing a "through and through" laceration of the anterior pericardium and apex of the left ventricle of the heart.
Cause of death: hypovolemic shock secondary to the stab wound. Dr. Ayro opined that either a single- or double-bladed knife must have been used to inflict the wound.
Abrasions were found on different parts of Calpito’s body.
Precy Calpito (victim’s mother) testified that the family spent P37,500 for wake, burial and 9-day prayers; she expressed the emotional impact of her son’s death.

Trial Evidence and Defense Contentions

The prosecution’s eyewitnesses included Lito Adjaro and Herbert Soriano; they identified the Quitlong brothers and Emilio Senoto in court and described their participation in holding, mauling and, as to Ronnie, stabbing the victim.
The recovered knife (Exhibit B) was identified by Adjaro as the weapon used.
The defense admitted the presence of appellants at the scene but denied participation in the stabbing.
Appellant Emilio Senoto testified that he went near the scene out of curiosity after parking his taxi to buy cigarettes and was arrested by policemen.
Appellant Salvador Quitlong denied participation and claimed he rushed to Mendoza’s puesto because Mendoza’s daughter (a classmate of his daughter) called for help; he stated he barely arrived to witness Mendoza stabbing Calpito.
Appellant Ronnie Quitlong similarly asserted he responded to Mendoza’s daughter and claims Mendoza had already stabbed Calpito when they arrived.
Sidewalk vendors Nonita de los Reyes and Lydia Cultura corroborated the Quitlongs’ account that it was Jesus Mendoza who stabbed Calpito; Nonita explained shock as reason for initial reticence; Lydia saw Mendoza in the melee and testified Mendoza embraced and stabbed a man in a white t-shirt.
Nonita and Alma Balubar followed appellants to the police station but did not immediately inform police of what they saw.

Trial Court Findings and Initial Sentencing

The RTC found Ronnie Quitlong, Salvador Quitlong and Emilio Senoto, Jr. guilty beyond reasonable doubt of murder and sentenced each to an indeterminate penalty stated in the RTC’s decision (as quoted in the record): an indeterminate penalty of twenty (20) years of reclusion temporal, as minimum, to forty (40) years of reclusion perpetua, as maximum.
The RTC ordered them to indemnify jointly and severally the heirs of Jonathan Calpito P50,000 for death; P35,700 as consequential damages; and P100,000 as moral damages, plus their respective shares in costs.
The RTC declared the knife (Exhibit “B”) forfeited in favor of the Government and directed the transfer of the accused to the custody of the Bureau of Corrections, Muntinlupa (pursuant to Circular No. 4-92-A of the Court Administrator).
The RTC archived the case against the remaining accused (Jesus Mendoza and several John Does) without prejudice to prosecution upon apprehension.

Issues on Appeal (Assignments of Error)

The Quitlong brothers (appellants) asserted the RTC gravely abused its discretion and acted without jurisdiction in:
- Finding conspiracy despite failure to allege cons
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