Case Summary (G.R. No. 170589)
Charges and Trial Background
The defendants were charged with double murder in an information dated November 6, 1956, at the Court of First Instance of Zamboanga del Sur. Following a trial, the Court found Sagario and Gui-e guilty beyond a reasonable doubt, qualifying their crime with evident premeditation and aggravating circumstances, including treachery and nighttime. Both were sentenced to death and were ordered to indemnify the heirs of Patrolman Paulino Ursais and Patrolman Jose Gomez, who were killed in the incident.
Key Events Leading to the Crime
On September 3, 1956, multiple persons, including Luis Gui-e and Antipas Sagario, were seen together in a store engaging in suspicious activities. The group later converged in Sagario's bodega, and subsequently, a raid was conducted on the municipal building where the two policemen were stationed. The officers were ambushed upon the arrival of the assailants, resulting in gunfire and the deaths of both Patrolman Ursais and Patrolman Gomez.
Encounter with Law Enforcement
Patrolman Ursais was on guard duty and was replaced by Patrolman Gomez at midnight. Shortly after Gomez took over, a group of armed men arrived, and he was threatened and shot by the assailants. The events that transpired were marked by panic, with Gomez attempting to escape after being shot. Accounts of the raid illustrate a coordinated and violent attack against the police presence in the area.
Dying Declarations and Statements
The dying declarations of Patrolman Gomez were key to the prosecution's case against Sagario and Gui-e. The first declaration was made in the presence of Chief of Police Turado and later to Governor Ebarle at the hospital, where Gomez identified his assailants. His statements were crucial as they directly implicated identified defendants while describing the circumstances of the violent raid.
Evidence of Conspiracy
The court examined various elements, including the history of conflict between Sagario, Gui-e, and the local police, which established a motive for the attack. The relationship between the accused and the police, coupled with their coordinated arrival at the scene of the crime, suggested a conspiracy to kill the officers, thereby qualifying the crime under Article 248 of the Revised Penal Code.
Defense and Alibi
Gui-e's defense rested on the assertion that he was not present at the crime scene during the attack. He provided an alibi claiming he was at Camp VII during the time of the murders. However, the proximity of the camp to the municipal building undermined his defense, as the distance could be covered in a short period, allowing for the possibility of him participating in the raid.
Judicial Findings and Affirmation of Guilt
The court affirmed the admissibility of Gomez's dying declarations, ruling that they met all requisite criteria for such evidence. The statements provided a clear identification of the assailants an
...continue readingCase Syllabus (G.R. No. 170589)
Case Background
- The case originated from an information filed on November 6, 1956, in the Court of First Instance of Zamboanga del Sur.
- Accused individuals: Antipas Sagario, Julian Fuentes, Resurreccion Espiga, Quirico Fuente, Matildo Castro, Marcelino Castro, Tomas Castro, Alejandrino Tabiao, Pacifico Danghil, Vicente Don, Andres Grado, and Luis Gui-e.
- They were charged with the crime of double murder.
Trial Court Proceedings
- The trial court found Antipas Sagario and Luis Gui-e guilty beyond a reasonable doubt of two murders.
- The court qualified the murders by evident premeditation and aggravating circumstances: treachery, use of motor vehicles, and nighttime.
- Sentences imposed:
- Death penalty for both Sagario and Gui-e.
- Joint and several indemnity of three thousand pesos each to the heirs of Patrolman Paulino Ursais and Patrolman Jose Gomez.
- The other accused were acquitted due to reasonable doubt.
Appeal and Accused's Death
- Both Sagario and Gui-e appealed the trial court's decision after their motion for reconsideration was denied.
- Antipas Sagario died on February 9, 1962, while in confinement, leading to the dismissal of the case against him on June 29, 1962.
Events Leading to the Murders
- On September 3, 1956, at approximately 2:00 PM, Luis Gui-e was seen with Sagario and other unidentified men drinking at a store.
- Later that day, a jeep owned by Sagario and another car were observed parked near Sagario's bodega with twelve individuals inside.
- At around midnight, the municipal building was raided by the group, leading to the deaths o