G.R. No. L-25403 March 15, 1968
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. LUIS CATALINO Y ARNISTO, defendant-appellant.

FACTS

The accused, Luis Catalino, was charged with the murder of his brother-in-law, Raymundo Gregorio, on June 2, 1961. The information alleged the qualifying circumstances of evident premeditation and treachery, and the aggravating circumstances of nighttime, dwelling, and relationship. The prosecution’s evidence established that at about 7:00 PM, the victim and his wife, Maria Catalino (the accused’s sister), were in their kitchen when the victim was suddenly stabbed from below through the bamboo slat floor. Maria immediately took a kerosene lamp, looked downstairs, and saw a man moving away, whom she recognized as her brother, the accused. The victim died later that evening from the fatal abdominal wound. The medical officer opined the wound was caused by a bladed instrument like a bolo. A re-enactment conducted five days later showed the accused’s footprints matched those found under the house, and Maria again identified him. Evidence revealed a long-standing feud between the accused and the victim over property and because the accused’s common-law wife (the victim’s sister) had left him, which the accused blamed on the victim. The defense presented an alibi, claiming the accused was at his son-in-law’s house all day and night. The defense also presented extra-judicial confessions from two detention prisoners, Rodrigo Julio and Federico Leyson, admitting to the killing, but they repudiated these confessions in court, claiming they were forced to sign them. The trial court found the accused guilty of murder and imposed the death penalty.

ISSUE

1. Whether the identification of the accused by the widow as the man she saw fleeing the scene is credible.
2. Whether the trial court correctly disregarded the extra-judicial confessions of the two detention prisoners presented by the defense.

RULING

The Supreme Court affirmed the conviction but modified the penalty to reclusion perpetua due to lack of the necessary votes for the death sentence.
1. On the identification: The Court found the widow’s identification of the accused credible. She recognized him by the light of the kerosene lamp she was carrying as he was only about two brazas away. Her identification was immediate, spontaneous, and consistent. Her motive to tell the truth was strong, given she was accusing her own brother. The re-enactment further corroborated her testimony.
2. On the extra-judicial confessions: The Court upheld the trial court’s rejection of the confessions of Julio and Leyson. They were repudiated in court, and the defense failed to prove their voluntary execution. The confessions were hearsay as the affiants denied their truthfulness on the witness stand. The claim of coercion by fellow detainees rendered them unreliable.
The Court found the killing was qualified by treachery, as the attack was sudden and from below the floor, ensuring the victim had no opportunity to defend himself. The aggravating circumstance of dwelling was present, as the crime was committed in the victim’s home. The penalty for murder is reclusion temporal in its maximum period to death. With the aggravating circumstance of dwelling and no mitigating circumstance, the penalty should be imposed in its maximum period. However, for lack of the necessary votes, the death penalty was reduced to reclusion perpetua. The decision was affirmed in all other respects.