G.R. No. 129896 ; November 23, 2000
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. JESUS MADRID Y YAP, WILLIAM MADRID Y VICTORIANO, JILL MADRID Y VICTORIANO and HILARION TINAO JR. Y MATEO, accused-appellants.

FACTS

The case stemmed from the killing of Camilo Malacad, a barangay tanod, after a fundraising dance in Barangay Danao Sur, Santa Fe, Romblon, on August 3, 1985. The prosecution presented eyewitness Adolfo Magcalayo, who testified that he saw accused-appellants Jesus, William, Jill Madrid, and Hilarion Tinao Jr. gang up on Camilo. He specifically stated that William hacked Camilo with a bolo, Jill struck him with wood, and Jesus urged the killing. Antonio Tasis corroborated this, testifying that when he tried to help Camilo, William hacked him, and Jesus attempted to stab him. The autopsy revealed Camilo sustained twelve injuries, indicating multiple assailants.
The defense presented a contrary version. Jesus Madrid claimed he was first stabbed by Antonio Tasis after a dispute at the dance. After wrestling the knife from Antonio, Jesus summoned his nephew, William. William testified that he then faced Camilo, who allegedly grappled with him for the knife, leading William to repeatedly stab Camilo in self-defense. The trial court convicted all four accused of Murder qualified by treachery and aggravated by abuse of superior strength, evident premeditation, and disregard of rank.

ISSUE

Whether the guilt of all accused-appellants for the crime of Murder was proven beyond reasonable doubt.

RULING

The Supreme Court modified the trial court’s decision. It acquitted Jesus Madrid, Jill Madrid, and Hilarion Tinao Jr. due to insufficient evidence of conspiracy. The Court found that the prosecution failed to prove their participation in the killing beyond reasonable doubt. The testimony of eyewitness Adolfo Magcalayo was deemed insufficient to establish a common criminal design among all four accused. His account did not convincingly show that Jesus, Jill, and Hilarion performed acts with the intent to kill Camilo, as their alleged acts of holding the victim could have had a different purpose, and the evidence did not adequately corroborate their direct participation in the fatal assault.
However, the Court upheld the conviction of William Madrid, but only for the lesser crime of Homicide. The Court found his guilt proven through his own judicial confession and corroborating evidence. It ruled that the qualifying circumstance of treachery was not established, as the initial attack on Camilo arose from a sudden altercation, not from a deliberate and methodical execution ensuring the victim’s defenselessness. The aggravating circumstances of abuse of superior strength, evident premeditation, and disregard of rank were also not proven. Thus, without any qualifying or aggravating circumstance, the killing constituted Homicide. William Madrid was sentenced to an indeterminate penalty of 8 years, 4 months, and 10 days of prision mayor medium as minimum, to 16 years, 2 months, and 20 days of reclusion temporal medium as maximum, and ordered to pay damages.