G.R. No. 146034 - People vs. Sube

The Regional Trial Court (RTC) convicted Lastide A. Sube, Rolando M. Menzon, and Felizardo Ontog of murder, sentencing them to reclusion perpetua.
The case involved the killing of Nicanor Solis, with Julio Solis, the victim's brother, witnessing the abduction and identifying the five perpetrators.
The accused-appellants presented inconsistent defenses, claiming coercion by their co-accused who were at large.
The RTC found Julio's testimony credible and straightforward, leading to the conviction of the accused-appellants.

The appellate court generally upholds the trial court's findings on witness credibility unless significant facts are overlooked or misinterpreted.
The trial court favored Julio's testimony, which was clear and unwavering during cross-examination, over the inconsistent accounts of the accused-appellants.
The accused-appellants' testimonies were deemed incredible, with contradictions regarding their involvement in the crime.

The evidence against the accused-appellants was primarily circumstantial, which can suffice for conviction if certain criteria are met.
Established circumstances included threats made to the victim, the accused entering the victim's home armed, the victim being last seen alive with the accused, and the discovery of the victim's body.
These circumstances formed a coherent chain of events leading to the conclusion of the accused-appellants' culpability.

Conspiracy can be inferred from the actions of the accused before, during, and after the crime, demonstrating a common purpose.
The accused entered the victim's house together, armed, and left carrying the victim, indicating a concerted effort.
The medical evidence supported that multiple instruments were used in the attack, further establishing the existence of conspiracy among the accused-appellants.

For evident premeditation to be established, clear proof of the decision to commit the crime, overt acts indicating commitment, and sufficient time for reflection must be present.
The court found no evidence of premeditation in this case, as there was no indication of planning or a time lapse before the execution of the crime.
Consequently, the crime was classified as homicide rather than murder.

The accused-appellants claimed voluntary surrender as a mitigating circumstance, which requires specific elements to be present.
Sube did not surrender voluntarily; he reported the incident to his employer, who then turned him over to the police.
Menzon was arrested by the police, disqualifying both from claiming voluntary surrender as a mitigating factor.

The crime of homicide is punishable by reclusion temporal, and without mi...continue reading