G.R. No. L-18508 and L-18509. February 29, 1964.
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ARSENIO MIRANDA, defendant-appellant. THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. EMILIANO DAJAY, RUPERTO PRINCIPE and ARSENIO MIRANDA, defendants-appellants.

FACTS

In Criminal Case No. 6784, appellants Emiliano Dajay, Ruperto Principe, and Arsenio Miranda were convicted of murder for the killing of Clemente Pastera. The prosecution evidence established that on the night of December 28, 1957, as Pastera and his wife were walking home from a dance, the three accused emerged from a banana grove. Dajay tapped Pastera on the shoulder and, when he turned, stabbed him in the abdomen. Principe then threw a stone that hit Pastera on the head. Pastera died two days later. Witness Jesus Sumagaysay testified to hearing the three conspire earlier that night, with Dajay declaring his intent to kill Pastera and the others promising support. In the related Criminal Case No. 6783, Miranda was also convicted of attempted murder for slashing Alfredo Castellanes, Pastera’s brother-in-law, when he rushed to aid the victim.
Dajay claimed self-defense, testifying that Pastera, allegedly drunk and aggressive, attacked him first and chased him with a knife, forcing him to grab a knife from a bystander and stab Pastera in retaliation. Defense witnesses supported this version, claiming Pastera was the initial aggressor. Miranda interposed an alibi, claiming he was at home during the incident. The trial court rejected these defenses and convicted all accused.

ISSUE

The core issue is whether the trial court erred in convicting the appellants, specifically in rejecting Emiliano Dajay’s claim of self-defense and Arsenio Miranda’s alibi, and in finding conspiracy based on the evidence presented.

RULING

The Supreme Court affirmed the convictions. The Court found Dajay’s claim of self-defense utterly untenable. For self-defense to prosper, unlawful aggression by the victim must be proven. The prosecution evidence, deemed credible by the trial court, showed a deliberate ambush, not a sudden quarrel. Dajay’s narrative—of being chased, disarming a bystander, and then stabbing his pursuer—was contrived and unsupported by the physical evidence and credible testimony. The Court noted the immediate report of the crime and the victims’ dying declarations identifying the attackers as part of the res gestae, which bolstered the prosecution’s case. The corroborative testimony of Sumagaysay regarding the conspiracy was accepted; his act of memorizing the conversation was deemed natural given the gravity of the plot.
Regarding Miranda, his appeal in the murder case was dismissed for being filed beyond the reglementary period, making his conviction final. Thus, his alibi defense became irrelevant, as the final judgment established his presence at the crime scene. The Court also found the motive established by the trial judge—romantic rivalry and familial discord over Pastera’s marriage to Thelma Castellanes—provided context for the crime. Conspiracy was duly proven by the coordinated actions of the appellants and their prior agreement. The penalties imposed were affirmed.