G.R. No. 85823 September 13, 1990
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ALEX PADRONES and JOSEPH BIARE @ “JOJO” BIARE, accused-appellants.

FACTS

The case stemmed from a brawl at the MGR Family Disco in Surallah, South Cotabato, in the early morning of August 4, 1986. The victim, Lorenzo Sison, was celebrating his birthday. Accused-appellants Alex Padrones and Joseph Biare arrived separately. Padrones testified that Sison approached him, squeezed his mouth, uttered a challenge referencing the powerful Sison family, and then attacked him with a knife. A general melee ensued involving Sison’s companions. Padrones claimed he was ganged upon and sustained injuries. Biare testified he remained seated throughout the fight and later helped the injured Padrones onto his motorcycle to take him home, learning only later that Sison had also been wounded. Sison died on August 21, 1986, from stab wounds. The prosecution’s case relied heavily on the testimony of alleged eyewitness Antonio Llaneta, the medical findings of Dr. Jose Velasquez, and an ante-mortem statement signed by Sison implicating both appellants.

ISSUE

The primary issue is whether the guilt of both Alex Padrones and Joseph Biare for the crime of Murder was proven beyond reasonable doubt.

RULING

The Supreme Court acquitted Joseph Biare but convicted Alex Padrones of the lesser crime of Homicide. The Court found the evidence against Biare insufficient to prove conspiracy or direct participation. The testimony of eyewitness Llaneta was deemed unreliable due to inconsistencies and his admitted participation in ganging up on Padrones, casting doubt on his credibility and vantage point. The ante-mortem statement of Sison was also rejected as hearsay, as it was not formally offered as a dying declaration and the prosecution failed to establish its required constitutional and procedural requisites. For Padrones, the Court found his culpability established, but not for Murder. The qualifying circumstances of treachery and evident premeditation were not proven. The incident was a sudden free-for-all arising from a heated confrontation, not a deliberate and stealthy attack. The victim was not deprived of a chance to defend himself, as he was an active aggressor in the initial scuffle. Consequently, without any qualifying or aggravating circumstances, Padrones’ criminal liability is for Homicide only, not Murder. He was sentenced to an indeterminate penalty and ordered to pay indemnity.