Title
People vs. Tambis y Baliong
Case
G.R. No. 124452
Decision Date
Jul 28, 1999
Pablito Tambis, drunk, decapitated a physically and mentally disabled victim, Leonardo Tagsa, using two bolos. Convicted of murder, penalty reduced to reclusion perpetua due to voluntary surrender and plea of guilty.

Case Summary (G.R. No. 124452)

Charges and Arraignment

On March 21, 1995, an information was filed against Pablito Tambis for murder, describing the violent act that led to the death of Leonardo Tagsa. The charge included allegations of premeditation, treachery, and abuse of superior strength. Upon arraignment on October 10, 1995, Tambis pleaded guilty, prompting the trial court to ensure that he fully understood the implications of his plea.

Evidence and Testimonies

Evidence presented included testimonies from witnesses who observed the altercation and Tambis' actions following the murder. Prosecution witness Agapito Dano observed Tambis with two bolos and later saw him publicly displaying the victim's severed head. Another witness, Edgar Regis, corroborated Dano's account, detailing the violent behavior Tambis exhibited while puncturing a motorcycle's tires to prevent someone from reporting the crime.

Accused's Defense

In his defense, Tambis acknowledged knowing the victim and admitted to the killing, though he cited intoxication as a reason for his actions. He claimed to have been unaware of his actions during the commission of the crime, although he later confessed to decapitating the victim. His defense was ultimately unpersuasive against the circumstantial evidence provided by the prosecution.

Trial Court's Decision

On January 23, 1996, the trial court found Pablito Tambis guilty of murder and imposed the death penalty, citing the heinous nature of the crime. The judge expressed concern over the accused's potential threat to society, grounding the decision in the applicability of Republic Act No. 7659, which categorizes certain crimes as heinous.

Automatic Review and Legal Arguments

The conviction was subject to automatic review due to the death sentence. Tambis did not contest his guilt but argued that the trial court failed to adequately address mitigating and aggravating circumstances leading to the death penalty. His primary defense was his claim of intoxication and his assertion that the crime's nature did not warrant such a harsh penalty.

Mitigating and Aggravating Circumstances

The reviewing court determined that two mitigating circumstances, voluntary surrender and a plea of guilty, warranted a reduction in the penalty. Conversely, the aggravating circumstance of abuse of s

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