GR L 16491; (November, 1962) (Digest)
G.R. No. L-16491 November 29, 1962
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. SIMEON PAULIN, MATIAS POROC, GREGORIO BAGABOYBOY and MANUEL YONGCO, defendants-appellants.
FACTS
The defendants-appellants were convicted of murder for the killing of Apolinario Tapayan. The victim and Simeon Paulin had a longstanding land dispute, which had resulted in reciprocal complaints for grave coercion. On December 16, 1949, a witness, Damian Baranela, overheard Paulin tell co-accused Gregorio Bagaboyboy, “let us kill Apolinario to eliminate him,” and warned Tapayan. The following evening, December 17, Tapayan was shot multiple times near his home. His common-law wife, Narcisa Mahidlawan, testified that immediately after hearing gunshots, she saw the four appellants walking hurriedly away from the scene in single file, each carrying firearms or flashlights.
The post-mortem examination revealed the victim suffered multiple gunshot wounds from different firearms. A shotgun and a carbine were later recovered. Ballistic examination confirmed two empty shells found at the crime scene were fired from the recovered shotgun, which was identified as belonging to Simeon Paulin. Witnesses testified to Paulin’s habitual carrying of this weapon and his absence from the area after the crime.
ISSUE
Whether the guilt of the appellants for the crime of murder was proven beyond reasonable doubt.
RULING
Yes, the Supreme Court affirmed the conviction but modified the penalty. The Court found the collective evidence sufficient to establish guilt beyond reasonable doubt. The existence of a motive rooted in the land dispute was established. The credible eyewitness account of Narcisa Mahidlawan placed all four appellants at the immediate vicinity of the crime moments after the shooting, fleeing together while armed. This testimony was corroborated by other witnesses who heard the gunshots and confirmed the appellants’ presence and conduct.
The physical evidence conclusively linked the appellants to the crime. The ballistic report matched shells from the scene to Paulin’s shotgun, and the nature of the wounds indicated the use of multiple firearms, consistent with the armed group seen by the witness. The appellants’ flight and Paulin’s cessation of carrying his shotgun after the incident were indicative of consciousness of guilt. The Court held that these circumstances, taken together, formed an unbroken chain leading to the reasonable conclusion that the appellants conspired to kill the victim. The qualifying circumstance of treachery was present, as the attack was sudden and rendered the victim defenseless, elevating the crime to murder. The penalty was properly modified to reclusion perpetua, there being no mitigating or aggravating circumstances.
