G.R. No. L-43528-29 & L-48067 October 10, 1980
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. VICENTE LABRINTO, ISIDORO LABRINTO, IÑIGO LABRINTO, RICARDO LABRINTO and BIENVENIDO LABRINTO, accused-appellants; THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ISIDORO LABRINTO and VICENTE LABRINTO, accused-appellants.

FACTS

The accused, Vicente Labrinto and his four sons, were charged with the murder of Simplicio Germones and the frustrated murder of Macario Odang. The crimes stemmed from a bitter family feud over a parcel of coconut land and related legal disputes. The prosecution evidence established that on September 30, 1974, Iñigo Labrinto initiated the attack by hacking Simplicio Germones as he descended from a coconut tree. Isidoro, Bienvenido, Vicente, and Ricardo Labrinto then successively joined in the assault, inflicting multiple fatal wounds. When Macario Odang intervened to pacify them, Isidoro and Vicente attacked and seriously wounded him. Vicente later withdrew his appeal in the murder case and had previously written a letter seeking forgiveness from the victim’s family, which was rejected.
The defense consisted of alibis and denial from all accused except Iñigo, who claimed sole responsibility, pleading self-defense and defense of property. He testified that he alone fought Macario and then Simplicio after a provocation. The trial court convicted all accused in a joint decision, sentencing them to reclusion perpetua for murder and imposing penalties for frustrated murder. The cases were consolidated on appeal to the Supreme Court due to their connection.

ISSUE

The primary issue is whether the trial court correctly convicted the appellants of murder and frustrated murder, and the proper determination of their criminal liability and penalties.

RULING

The Supreme Court affirmed the convictions but modified the penalties. The Court found the prosecution’s eyewitness accounts credible and conclusive, establishing conspiracy among the appellants in the murder of Germones. Their collective and successive actions demonstrated a unity of purpose to kill. Iñigo’s claim of sole responsibility was rejected as contrary to the evidence. The Court also upheld the conviction for the frustrated murder of Macario Odang.
Regarding penalties, the Court ruled that the qualifying circumstance of treachery was properly appreciated for the murder charge, as the initial attack on Germones while he was defenseless was sudden and unexpected. However, the aggravating circumstances of evident premeditation and abuse of superiority were not proven. For the frustrated murder, the Court found that the intent to kill Macario was not sufficiently established, as the wounds inflicted were not fatal. Thus, the crime was properly classified as attempted murder, not frustrated murder.
The Court applied mitigating circumstances. Iñigo, Bienvenido, and Isidoro were credited with voluntary surrender, warranting a reduction of their penalty for murder to an indeterminate sentence. Ricardo Labrinto was found to be a minor at the time of the crime, entitling him to a privileged mitigating circumstance that lowers the penalty by one degree. Vicente’s appeal in the murder case having been withdrawn, his conviction stood, but his penalty for the crime against Macario was also reduced. The dispositive portion modified the sentences accordingly.