Title
Republic vs. Clemente
Case
G.R. No. L-23463
Decision Date
Sep 28, 1967
Barrio lieutenant Reyes Matnog was fatally stabbed in 1962; Clemente brothers convicted, with Rosalio claiming self-defense. Supreme Court modified charges, ruling homicide, not murder, and considered mitigating circumstances.

Case Summary (A.C. No. 6767)

Incident Overview

Reyes Matnog was fatally wounded at approximately 3 PM after attending a celebration for Pedro Baniega’s election as barrio lieutenant of San Miguel. Post-mortem investigations revealed that Matnog sustained multiple stab wounds, leading to his death from internal hemorrhage and shock, as confirmed by the autopsy report from the Rural Health Officer.

Investigation and Charges

Following the incident, Chief of Police Victorino F. de Leon conducted an investigation based on witness statements from Basilio Pornelos and Isabel Medala, which led to the preparation of a crime scene sketch. Subsequently, on March 15, 1962, the three Clemente brothers were charged with murder, alleging that they conspiringly attacked Matnog using bladed weapons.

Arraignment and Prosecution's Evidence

During arraignment, the defendants pleaded not guilty. The prosecution presented testimonies, including that of Dr. Antonio Ofiana regarding Matnog’s death, and eyewitnesses who implicated the Clemente brothers. Only Pablito Seriguini could testify in court regarding the events he witnessed, where he claimed that Rosalio Clemente attacked Matnog with a double-bladed knife while Carlos and Pascual Clemente later joined in on the assault.

Defense Argument

The defense presented alibis for Carlos and Pascual Clemente, claiming they were gathering firewood at the time of the attack. Rosalio Clemente testified that he acted in self-defense during an altercation with Matnog. Defense witnesses corroborated their alibis but faced scrutiny because their testimonies appeared inconsistent and unconvincing.

Trial Court Decision

The trial court found all three Clemente brothers guilty, emphasizing the suddenness of the attack and the treachery involved, as Matnog was unarmed and defenseless when he was fatally attacked. The court sentenced Pascual and Carlos to reclusion perpetua for murder, while Rosalio received a lesser sentence for homicide, with additional civil liabilities for damages to Matnog's heirs imposed on all defendants.

Appeal and Criminal Responsibility

The defendants appealed, challenging the credibility of the eyewitness testimony. However, the court maintained that Seriguini's testimony was credible and consistent with physical evidence. The court also highlighted inconsistencies in the defense's case and maintained that elements of treachery characterized the killing.

Judgment on Appeal

Ultimately, the appellate court modified the judgment by reducing the penalties. Rosalio's liability was mitigated by his voluntary s

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