G.R. No. L-26241 - People vs. Vicente

Case Summary (G.R. No. L-26241)

Factual Background: The Attack and the Medical Findings

The Supreme Court found the core facts to be undisputed. On the night of 29 October 1965, Jaime Soriano was attacked and stabbed in front of the public market in Asingan, Pangasinan, and he died that same evening. The autopsy report of the Municipal Health Officer described multiple injuries, including a crescent-shaped flap wound on the scalp over the right anterior parietal area, a stab wound over the left cheek exposing the cheek bone, five stab wounds in the chest and stomach (frontal), a stab wound penetrating the right thoracic cage, another stab wound on the mid-section of the left arm, and a clean-cut wound between the thumb and index finger almost severing the thumb down to the base. At the back, the deceased sustained, among others, an occipital lacerated wound involving the entire thickness of the scalp, a stab wound at the posterior base of the neck, additional stab wounds in the back region, scratch and stab wounds over the scapular and arm areas, and a clean-cut wound forming a skin flap near the elbow joint.

The autopsy further indicated that the stab wounds were inflicted by two kinds of sharp-edged instruments: the crescent-shaped wound could have been caused by a broken bottle, while the occipital wound could have been caused by a blunt instrument. The time of death was estimated between 7:00 and 8:30 p.m. of 29 October 1965, and the cause of death was shock due to severe hemorrhage secondary to multiple stab wounds. The medical evidence showed that six of the injuries were fatal.

Filing of the Case and the Charges

A criminal complaint for murder was filed on 30 October 1965 in the Municipal Court of Asingan, Pangasinan, against Jose Vicente, Ernesto Escorpizo, Alfredo Bedonio, and Ambrocio Cabiles, Jr. The information was subsequently filed in the Court of First Instance of Pangasinan on 18 April 1966 (Crim. Case No. 22747-I), charging the accused with having conspired to treacherously attack and assault Jaime Mariano Soriano, inflicting injuries that caused his death.

Prosecution Evidence: Eyewitness Account

At trial, the prosecution relied primarily on the testimony of eyewitness Virgilio Sarmiento. Sarmiento narrated that in the evening of 29 October 1965, Jaime Soriano, Florentino Arellano, and Sarmiento were in the store of Arsing Fernandez in the public market of Asingan, buying cigarettes. As they counted their money, Jose Vicente approached, placed his hands on Soriano’s shoulder, and asked in Ilocano why Soriano was always with “Boy Canaveral,” suggesting that Soriano might have been his companion when he shot “Manong Idio.” When Soriano denied the allegation, Vicente immediately pulled a dagger from his waist and thrust it several times into Soriano, who fell to the ground face down. Ernesto Escorpizo then stabbed Soriano repeatedly using a small knife. Vicente’s companions, including Alfredo Bedonio and a person later identified as Ambrocio Cabiles, Jr., picked up stones and stoned Soriano while he lay prostrate. Sarmiento and Arellano, who witnessed the assault, were likewise attacked with stones, forcing them to move away before they fled from the scene.

The Defendants’ Theory of Defense: Alibi

All four accused presented alibi as their defense, claiming they were elsewhere when the stabbing occurred. Ambrocio Cabiles, Jr. testified that around 7:30 p.m. of 29 October 1965 he was at the Pantranco station in Urdaneta, Pangasinan, seeking a ride back to Asingan after a trip to Concepcion, Tarlac. He stated that when Vicente, Escorpizo, and Bedonio arrived, the group decided to hike to Asingan. Upon reaching barrio Dumampot, they were allegedly met by Asingan policemen and taken to the municipal building where they were jailed. Cabiles further claimed that on 1 November 1965 the police made him sign certain papers without explaining their contents, and that the papers turned out to be a statement narrating his alleged participation in the killing.

Alfredo Bedonio claimed he was at the MGM canteen in Urdaneta drinking beer from 6:00 p.m. until 7:30 p.m. of that evening with Escorpizo. He stated that Vicente left briefly to get clothes and returned only after 7:30 p.m., and that the group then went to the Pantranco station where they met Cabiles, who allegedly told them there was no more trip to Asingan. According to Bedonio, they decided to hike and were arrested at barrio Dumampot, brought to the municipal building, and jailed. He added that the police did not ask him to sign a written statement and he denied participation when investigated.

Ernesto Escorpizo testified that on the morning of 29 October 1965, Vicente invited him and Bedonio to go fishing in barrio Camantiles, Urdaneta, where they stayed until 5:30 p.m. They then went to the MGM canteen, drank beer, left at around 7:30 p.m., and proceeded to the Pantranco station to go home to Asingan. He stated that Cabiles informed them that the last bus had left and they decided to walk. Escorpizo claimed that at around 10:00 p.m., in barrio Dumampot, they were arrested by Asingan police, brought to the municipal building, and jailed for the killing of Jaime Soriano. He further testified that on 1 November 1965 he was maltreated at the plaza, then returned and made to sign papers (Exhibit C) after being threatened.

Jose Vicente testified that on the morning of 29 October 1965, he went to barrio Camantiles, Urdaneta, Pangasinan, to visit his wife and child staying with relatives. He claimed he was accompanied by Bedonio and Escorpizo and that they stayed until 5:30 p.m., when they went to the MGM canteen and drank beer. He admitted he remembered leaving his clothes and returned at about 6:30 p.m., then rejoined his companions in the poblacion. He stated that after drinking another bottle of beer, the three proceeded to the Pantranco station. He claimed they were told by Cabiles there was no more trip to Asingan, so they decided to hike. Vicente claimed that around 10:00 p.m., when they reached barrio Dumampot, they were stopped by Asingan policemen and jailed for the killing of Soriano. He alleged that on 10 December 1965 he was brought out of jail, directed to sign a paper by policeman Juan Canaveral, and he signed because he believed the threat would be carried out, without knowing the contents of Exhibit A.

Trial Court’s Ruling: Conviction for Murder and Treachery

On 8 June 1966, the trial court found all four accused guilty of murder as charged and held that the stabbing of Soriano was characterized by treachery. It found no mitigating or aggravating circumstances and therefore sentenced each accused to life imprisonment. The court also ordered joint and several indemnification to the heirs of the deceased in the amount of P6,000.00, plus the payment of costs.

The Appeal: Contentions and the Narrow Issue of Credibility

In the Supreme Court appeal, the accused-appellants contended that the trial court erred in: (a) giving credence to eyewitness Virgilio Sarmiento; (b) according weight to the extra-judicial confessions executed by Jose Vicente, Ernesto Escorpizo, and Ambrocio Cabiles, Jr. (Exhibits A, B, and C); and (c) imposing the penalty of life imprisonment. The Supreme Court treated the matter as hinging primarily on credibility of witnesses, applying the established principle that appellate courts will not disturb the trial judge’s factual conclusions absent proof of misappreciation, given the trial court’s opportunity to observe witness demeanor.

Credibility of the Eyewitness and Corroboration

The Supreme Court affirmed the trial court’s acceptance of Sarmiento’s identification of the accused as the participants in the assault. The Court noted that Sarmiento had executed a statement before the police shortly after the incident, naming Jose Vicente, Ernesto Escorpizo, Alfredo Bedonio, and another person whom he did not initially know by name but could recognize; the police arrested the four accused about two hours later while they were walking together in barrio Dumampot. The Court viewed this as consistent with the reliability of the identification.

The Court also found Sarmiento’s testimony corroborated by the medical evidence. It held that Sarmiento’s assertion that Vicente conversed with Soriano and then pulled out a bladed weapon and stabbed Soriano many times was supported by the location and direction of the fatal stab wounds in the chest and stomach. The Court reasoned that these injuries indicated a right-handed stabbing by a person in front of the victim while Soriano was standing, and it tied Escorpizo’s role after Soriano fell face down to the superficial wounds at the back and arms, as well as to the autopsy’s conclusion that two kinds of bladed weapons were used.

As to the defense attempt to impeach Sarmiento, the Court addressed testimony by the father of the deceased and counsel for the accused suggesting that Sarmiento denied knowing the assailants during the wake. The Court held that even if such denial occurred, it did not destroy the earlier identification because the statement naming the accused had already been given to the police prior to the alleged denial. It further explained that fear of retaliation from the offenders’ relatives or sympathizers could account for any later reluctance. The Court noted that Sarmiento knew the accused personally and had no motive on record to testify falsely against them. It stressed that the identification survived extensive cross-examination.

Extra-Judicial Confessions: Rejection of the Claims of Improper Preparation

Regarding the accused’s claims that the extra-judicial statements were prepared by the police and signed without knowledge of their contents, the Supreme Court rejected the defense version. The Court found that Mayor Leonardo Carbonell, before whom the statements appeared to have been executed, testified as to due execution. It also observed that the accused admitted they had no valid reason to bel

Case Syllabus (G.R. No. L-26241)

Parties and Procedural Posture

The People of the Philippines prosecuted Jose Vicente, Ernesto Escorpizo, Alfredo Bedonio, and Ambrocio Cabiles, Jr. for the killing of Jaime Mariano Soriano.
The Court of First Instance of Pangasinan convicted all four accused of murder and sentenced each to life imprisonment.
All the accused appealed to the Supreme Court on the sole issue of credibility of witnesses.
The Supreme Court reviewed the conviction while applying the established rule on restraint toward the trial court’s assessment of witness demeanor.

Key Factual Allegations

On the night of 29 October 1965, Jaime Soriano was attacked and stabbed in front of the public market in Asingan, Pangasinan, and died that same evening.
An autopsy report disclosed multiple injuries inflicted by two kinds of sharp-edged instruments, including a crescent-shaped flap wound consistent with a broken bottle and an occipital wound that could have been caused by a blunt instrument.
The autopsy placed the time of death between 7 and 8:30 p.m. on 29 October 1965, and identified the cause of death as shock due to severe hemorrhage secondary to multiple stab wounds.
A criminal complaint for murder was filed on 30 October 1965 in the Municipal Court of Asingan, and an information was filed in the Court of First Instance of Pangasinan on 18 April 1966.
The prosecution evidence, primarily through eyewitness Virgilio Sarmiento, established that Jose Vicente confronted Soriano, pulled a dagger, and repeatedly thrust it at Soriano.
The evidence further showed that Ernesto Escorpizo stabbed Soriano with a small knife after Vicente’s initial attack.
The evidence also alleged that Alfredo Bedonio and Ambrocio Cabiles, Jr. threw stones at Soriano after he fell, and that stones were also thrown at Sarmiento and Florentino Arellano, prompting their flight.
The defense was alibi, with each accused testifying to being at or near places other than the crime scene at the relevant time.

Medical and Physical Evidence

The autopsy described numerous wounds, including stab wounds in the chest and stomach with injuries to the heart’s big vessels and lungs.
Several wounds were described at specific body areas, including the head, back of the neck, arms, and a clean-cut wound between the thumb and index finger almost severing the thumb.
The prosecution used the medical findings to corroborate the eyewitness narration regarding the manner and location of the fatal injuries.
The fatal wounds were treated as significant indicators of the position, instrument characteristics, and directionality of the stabbing.
The Court used the wound directions and severity to infer that the stabbing was executed by a right-handed person located in front of the victim while the victim was standing.

Witness Identification and Credibility

The Court treated the case as turning on the credibility of witnesses, particularly the reliability of eyewitness Sarmiento’s identification of the accused.
The Court reiterated the rule that the trial judge’s factual conclusions based on witness demeanor should not be disturbed absent proof of misappreciation of evidence.
The Court held that Sarmiento’s direct and positive declaration established the identity of the persons who assaulted Soriano.
The Court found that Sarmiento executed a statement before the police shortly after the incident naming Jose Vicente, Ernesto Escorpizo, Alfredo Bedonio, and another person he initially did not know by name but could recognize, and that he later recognized Cabiles during trial.
The Court considered the immediate police arrest of the four accused walking together in barrio Dumampot as consistent with the statement Sarmiento made after the incident.
The Court found Sarmiento’s testimony credible because it was clear, straightforward, and convincing, and because material portions were corroborated by medical evidence.

Corroboration by Autopsy Findings

The Court found that Sarmiento’s account of the first stabbing by Vicente was supported by the number and position of the fatal chest and stomach wounds.
The Court concluded that the fatal wounds’ direction and seriousness supported that the stabbings were made by a sharp instrument with a width described as about 3 cm. while the victim was standing.
The Court also found that Sarmiento’s account that Escorpizo stabbed Soriano after Soriano fell face down was corroborated by superficial wounds on the back and arms and by the medical report indicating the use of two different kinds of bladed weapons.
The Court dismissed the claim that later denials by Soriano’s father and counsel during the wake weakened the earlier identification.

Treatment of Alleged Wake Denial

The record showed that during the wake, when asked about the identity of the assailants, Sarmiento allegedly denied knowledge.
The Court held that even if such deni