G.R. No. L-38172 July 15, 1981
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. SEGUNDINO UTRELA, accused-appellant.

FACTS

On March 28, 1971, Feliciana Areola and her nine-year-old son Conrado were harvesting bananas. The accused, Segundino Utrela, who was married to Feliciana’s sister-in-law, suddenly emerged and shot Feliciana in the thigh. Fleeing for help, Feliciana left Conrado behind. Utrela then surrendered to the mayor, confessing he had killed the boy with a bolo and hidden the body. He surrendered the weapon and guided police to the concealed cadaver the next day. The autopsy revealed Conrado suffered near-decapitating wounds inflicted from behind with a sharp instrument.

ISSUE

Whether the trial court correctly convicted Segundino Utrela of Murder for the killing of Conrado Areola and Frustrated Murder for the shooting of Feliciana Areola.

RULING

Yes, the Supreme Court affirmed the conviction. The legal logic rests on the conclusive proof of Utrela’s guilt beyond reasonable doubt. His defense of accidental shooting was rejected as a fabrication, contradicted by his own actions. His voluntary surrender and oral confessions to the mayor and police officers, corroborated by his act of leading authorities to the hidden body and surrendering the murder weapon, constitute direct and circumstantial evidence of his culpability. For Conrado’s death, the killing was qualified as Murder due to treachery; the attack from behind with a bolo, which nearly decapitated the child, ensured the victim had no opportunity for defense. The killing of Feliciana constituted Frustrated Murder, as all acts of execution were performed, and her survival was due to timely medical intervention independent of the accused’s will. The Court upheld the penalties, including the death sentence for Murder, as modified by the constitutional prohibition at the time, considering the aggravating circumstance of disregard of age.