GR 34386; (February, 1991) (Digest)
G.R. No. 34386 ; February 7, 1991
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. LUDOVICO C. DOCTOLERO alias “ECOY,” CONRADO C. DOCTOLERO alias “CONDRING,” and VIRGILIO C. DOCTOLERO alias “VERGEL,” accused-appellants.
FACTS
On the evening of November 8, 1970, in Barrio Binday, San Fabian, Pangasinan, a violent incident occurred resulting in multiple deaths. The prosecution evidence established that accused-appellant Ludovico Doctolero initially assaulted Marcial Sagun on the road. Frightened, Lolita de Guzman Oviedo fled to the house of Marcial Sagun. Subsequently, Ludovico and his brothers, Conrado and Virgilio, were seen throwing stones at that house. Later, Epifania Escosio and Lolita de Guzman were found killed inside the house, and Lolita’s infant son, Jonathan Oviedo, was injured.
Immediately thereafter, the three brothers, now joined by their father Antonio, encountered their uncle, Marcelo Doctolero, on the road near the house. When Marcelo admonished them, they responded with threats and hacked him to death. The trial court convicted Ludovico as a principal and Conrado and Virgilio as accomplices to three counts of murder and slight physical injuries.
ISSUE
The primary issue is whether the Court of Appeals correctly affirmed the convictions and the classification of the accused’s criminal liability.
RULING
The Supreme Court affirmed the convictions but modified the penalties and the nature of liability. The Court upheld the factual findings of the trial court, giving full respect to its assessment of witness credibility. It found no reason to deviate from the conclusion that the appellants were responsible for the killings of Epifania Escosio, Lolita de Guzman Oviedo, and Marcelo Doctolero. The qualifying circumstance of treachery was properly appreciated for the murders committed inside the house, as the victims were attacked while defenseless. However, the Court agreed with the trial court that no conspiracy was proven among the appellants. Thus, Ludovico was correctly held as a principal, while Conrado and Virgilio were properly classified as mere accomplices, whose liability is one degree lower than that of the principal.
The penalty for the injury to Jonathan Oviedo was corrected from slight to less serious physical injuries, as the medical attendance lasted fifteen days. During the appeal, Virgilio Doctolero died, which extinguished his criminal liability but not his civil liability. The civil indemnity for the heirs of each victim was increased to P50,000.00, applicable to Conrado and Virgilio’s estate. The judgment against Ludovico, who had withdrawn his appeal, remained final. The decision was modified accordingly, imposing on Conrado three indeterminate sentences for the murders and a corrected penalty for the physical injuries.