G.R. No. 169084; January 18, 2012
People of the Philippines, Plaintiff-Appellee, vs. Melanio del Castillo y Vargas, Hermogenes del Castillo y Vargas, Arnold Avengoza y Dogos, Felix Avengoza y Dogos, Rico del Castillo y Ramos, and Joven del Castillo y Abesola, Accused-Appellants.
FACTS
On March 21, 2000, at around 9:00 p.m. in Sitio Bulihan, Brgy. Balete, Batangas City, accused-appellants, who are all related by consanguinity or affinity, allegedly conspired to attack, hack, and stab Sabino Guinhawa, Graciano Delgado, and Victor Noriega with bolos, a kitchen knife, and a pointed instrument, causing their deaths. Three separate Informations for Murder were filed against them. The accused pleaded not guilty.
The prosecution presented eyewitness Froilan Perfinian, who testified that on the night of the incident, he heard pleas for mercy and saw from about six meters away, under a bright moon, all six accused surrounding and assaulting the three victims. He identified each accused, noting he was a godfather to Hermogenes’s son and the others often passed by his house. He specifically recounted: Arnold stabbed Graciano; Rico hacked Graciano; Hermogenes and Felix pursued and hacked Victor; and Melanio and Joven pursued Sabino. Perfinian went home, later left for Marinduque out of fear, and returned to give a statement after learning of the arrests.
PO3 Pablo Aguda Jr. responded to a report on March 22, 2000, and found the three bodies with hack wounds. An informant, Rene Imbig, mentioned seeing the six accused running with bolos that night. Police went to the accused’s houses, found them abandoned, but recovered a blood-stained knife from Melanio’s house. Hermogenes, who was at the police station, informed them the others had fled to Antipolo, Rizal. There, police arrested Melanio (from whom a bolo was recovered) and the other accused. The accused admitted disposing of some clothes in the Pasig River. Further investigations led to the recovery of more blood-stained clothing and a bolo from Hermogenes’s wife. It was also learned that prior to the killings, Melanio had uttered threats after being cheated in a cockfight.
Dr. Luz Tiuseco conducted post-mortem examinations and certified the victims died from hypovolemic shock due to multiple stab and hack wounds. The victims’ relatives testified to incurring burial expenses.
The defense, through the accused and Winifreda del Castillo (Hermogenes’s wife), presented a different version. Arnold and Joven claimed self-defense and defense of a stranger. They testified that on the night in question, while escorting Winifreda and her son home, three men appeared, one held Winifreda, and when Arnold tried to help, the men reached for their waists, prompting him to hack one. He claimed he hacked another man who got mad. They then brought Winifreda to Melanio’s house, warned him to leave due to dead persons nearby, and Arnold threw his bolo into the river. The other accused (Melanio, Hermogenes, Rico, Felix) interposed denial.
ISSUE
The core issue is whether the guilt of all accused-appellants for the crime of Murder was proven beyond reasonable doubt.
RULING
The Supreme Court affirmed the conviction of all accused-appellants for three counts of Murder. The Court found the eyewitness account of Froilan Perfinian credible, positive, and categorical. His identification of all six accused was reliable given the bright moonlight, his proximity (six meters), and his prior familiarity with them. His testimony was consistent and corroborated by physical evidence and the accused’s own conduct (flight, disposal of evidence, and prior threats).
The defenses of denial and alibi were rejected as weak and inherently unreliable, especially when weighed against positive identification. The claim of self-defense by Arnold and Joven failed because they did not prove unlawful aggression by the victims; their narration of events was deemed improbable and contrived. The Court found that all accused acted in concert, indicating conspiracy. The qualifying circumstance of treachery was present as the attack was sudden and unexpected, giving the victims no chance to defend themselves. The circumstance of abuse of superior strength was absorbed in treachery.
The Court modified the penalties. As the death penalty was prohibited at the time of judgment, each accused was sentenced to reclusion perpetua without parole for each count of murder. They were held jointly and severally liable to pay civil indemnity, moral damages, and temperate damages to the heirs of each victim, with legal interest. Actual damages were not awarded due to lack of competent receipt evidence, but temperate damages were granted in lieu thereof.