GR 38398; (September, 1980) (Digest)
G.R. No. L-38398 September 30, 1980
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. JAIME CLORES and MARIO HOLIDAY, defendant-appellants.
FACTS
Appellants Jaime Clores and Mario Holiday, both inmates at the New Bilibid Prisons Hospital, were charged with murder and attempted murder as a complex crime. On December 20, 1971, they entered an adjoining ward where inmate Bayani Salido was working on a project. Clores approached Salido from behind and stabbed him. Simultaneously, Holiday approached attendant Benito Satorre, who was lying on his bed, and stabbed him twice. Satorre defended himself, causing Holiday to retreat. Salido died from his wounds. During arraignment, Clores pleaded guilty, but the trial court, following mandatory procedure, required evidence presentation. The prosecution presented eyewitness accounts and statements. The defense presented a different version, claiming Clores acted after being assaulted by Salido and that Holiday was merely present to buy cigarettes, with both alleging their confessions were coerced.
ISSUE
The core issues were whether the crimes constituted a single complex crime under Article 48 of the Revised Penal Code, whether the killing was qualified by treachery or evident premeditation to constitute murder, and whether conspiracy between Clores and Holiday was proven beyond reasonable doubt.
RULING
The Supreme Court modified the trial court’s decision. It ruled that the crimes did not constitute a complex crime under Article 48, as they involved two distinct acts against two different victims without a single criminal impulse. The Court found that treachery was not established beyond reasonable doubt. The location of Salido’s wounds suggested a frontal attack, and the eyewitness testimony was deemed unreliable on this point. Evident premeditation was also ruled out due to the suddenness of the altercation. Consequently, Clores’s act was homicide, not murder. The aggravating circumstance of serving a sentence at the time of the crime was applied. Conspiracy was not proven; therefore, Holiday could not be held liable for Salido’s death. The charge of attempted murder against Holiday for the attack on Satorre was also not proven beyond reasonable doubt. Clores was convicted of homicide and sentenced to an indeterminate penalty. The indemnity was increased. Holiday was acquitted of all charges.