Case Summary (G.R. No. 231540)
Charges and Lower Court Decision
Juan and Severo Padernal were convicted by the Circuit Criminal Court of Lucena City for the murder of Geminiano de Leon and sentenced to reclusion perpetua. They were also convicted of lesiones leves (less serious physical injuries) against Marianito de Leon and sentenced to 15 days of arresto menor (minor arrest). Rosendo Perpenan, Rito Monterey, and Macario Monterey were acquitted. The defendants appealed the murder conviction.
Facts Leading to the Incident
On the morning of January 30, 1965, Geminiano, his common-law wife Fabiana Rosales, his son Marianito de Leon, and another individual encountered Pio Ricohermoso regarding Geminiano's share from the palay (rice) harvest on his land cultivated by Ricohermoso. Initially, Ricohermoso offered to give palay to Geminiano, but by the afternoon, he adopted a hostile stance, refusing and threatening not to give any palay.
When Geminiano returned to Ricohermoso’s house, a prearranged assault occurred. Ricohermoso attacked Geminiano with a bolo (machete) from the left while Severo Padernal attacked from the right with an axe. Geminiano pleaded for mercy to Severo Padernal but was fatally wounded by both attackers. Meanwhile, Juan Padernal grappled with Marianito de Leon, disarming him and preventing him from firing a rifle at the assailants. Geminiano died from deep wounds that severed the carotid artery and jugular vein, as certified by medical evidence.
Appellants' Version and Trial Court Rejection
The appellants contended that Ricohermoso was solely responsible and that he acted in self-defense after Geminiano allegedly attacked him first. They sought to exculpate both Juan and Severo Padernal by asserting lack of direct participation or conspiracy. However, Severo Padernal’s withdrawal of his appeal signified acceptance of the prosecution’s version, thereby undermining the appellants’ defense.
Issue on Appeal: Conspiracy and Joint Criminal Liability
The sole issue on appeal regarding Juan Padernal was whether he conspired with Ricohermoso and Severo Padernal to kill Geminiano de Leon. The trial court found conspiracy based on the unity of purpose and coordinated conduct in attacking the victim. Juan’s actions in disarming Marianito, the son of the victim, at the exact time Ricohermoso and Severo assaulted Geminiano, were found to be indispensable to the commission of the killing.
Rejection of Justifying Circumstance Invoked by Juan Padernal
Juan alleged the justifying circumstance of avoiding a greater evil by preventing Marianito from shooting. The court ruled this defense untenable, as the act was intended to ensure that the assailants avoided injury while killing Geminiano. Disabling Marianito was an act to facilitate the homicide, not to prevent greater harm, and hence did not qualify as a legitimated justification under Article 11, paragraph 4, of the Revised Penal Code.
Legal Basis for Holding Juan Padernal Liable
Under the Revised Penal Code, participation in a criminal conspiracy entails coordinated action toward a common criminal purpose. Despite not striking the fatal blow himself, Juan Padernal’s timely restraint of Marianito was an essential part of the plan, confirming his status as a co-principal in the murder. The court emphasized that their actions were like a well-rehearsed execution, demonstrating premeditation and unity of intent.
Appreciation of Treachery as a Qualifying Circumstance
The killing was committed with treachery (alevosia), a qualifying circumstance that aggravates criminal liability. Evidence showed Geminiano’s hands raised in plea when he was stabbe
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Facts of the Case
- On January 30, 1965, at around 9:00 AM, Geminiano de Leon, his common-law wife Fabiana Rosales, his son Marianito de Leon, and Rizal Rosales encountered Pio Ricohermoso in Barrio Tagbacan Silangan, Catanauan, Quezon.
- Geminiano owned land in said barrio which Ricohermoso cultivated as kaingin. Geminiano asked for his rightful share of the palay harvest, requesting at least the opportunity to taste the palay.
- Ricohermoso initially responded conciliatorily, inviting Geminiano to his house to take palay any time.
- Later, around 2:00 PM, when Geminiano returned to collect his share, Ricohermoso became hostile and refused to give the palay, stating, “Whatever happens, I will not give you palay.”
- As an apparent prearranged plan executed, Ricohermoso unsheathed a bolo and approached Geminiano from the left, while Severo Padernal (Ricohermoso’s father-in-law) armed himself with an axe and approached from the right.
- Geminiano raised his hands pleading with Severo Padernal not to fight, but Ricohermoso stabbed Geminiano on the neck with the bolo. Geminiano fell face downward and was further hacked on the back by Severo with an axe.
- Simultaneously, Juan Padernal (Ricohermoso's brother-in-law and Severo’s son) embraced Marianito from behind, immobilizing him and wresting away his rifle as they grappled downhill, causing Marianito to lose consciousness.
- Geminiano died at 2:00 PM the same day from fatal wounds inflicted by the bolo and axe.
- Medical examination by Dr. Isabela A. Matundan confirmed critical injuries including a deep neck wound severing carotid artery and jugular vein, a deep back wound, and other injuries consistent with assault.
Charges, Trial, and Court Decisions
- The Circuit Criminal Court at Lucena City convicted Severo Padernal and Juan Padernal of murder, sentencing each to reclusion perpetua with an order to pay 12,000 pesos jointly to Geminiano’s heirs, along with costs.
- They were also convicted of lesiones leves (light physical injuries) for the assault on Marianito de Leon, sentenced to 15 days of arresto menor and payment of costs.
- Rosendo Perpenan, Rito Monterey, and Macario Monterey were acquitted.
- The decision was appealed by Severo and Juan Padernal; however, Severo later withdrew his appeal, thus affirming the lower court’s findings against him.
- The main issue on appeal focused