G.R. No. L-17321; November 29, 1963
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. SANTOS DONIEGO, defendant-appellant.

FACTS

On the night of July 1, 1957, during a barrio fiesta dance in Gonzaga, Cagayan, a fight erupted where the appellant’s son, Domingo Doniego, was stabbed to death by Camilo Ragual. Upon learning of his son’s death, Santos Doniego arrived at the scene armed with a bolo. After being informed that Ragual was the assailant, Doniego went upstairs to the dance area and, in a violent rage, began attacking people. He stabbed Vicente Pescador, rural policeman Anselmo Garcia, and Avelino Paet. He then proceeded to stab rural policeman Ciriaco Palor and Maximo Viernes, the barrio council secretary. Garcia, Palor, and Viernes died from their wounds. Anselmo Garcia, before his death, executed an ante mortem statement identifying Doniego as his assailant. The appellant denied the accusations, claiming he merely retrieved his son’s body and did not commit the killings, alleging that the eyewitnesses testified against him due to ulterior motives related to another case.

ISSUE

Whether the trial court correctly convicted Santos Doniego of three counts of murder qualified by treachery and evident premeditation.

RULING

The Supreme Court affirmed the conviction but modified the crimes from murder to homicide and reduced the penalty. The legal logic centered on the absence of the qualifying circumstances. The Court found that the evidence did not establish treachery (alevosia). While the initial attack on Vicente Pescador may have been sudden, the subsequent assaults on the other victims, including the three deceased, could not be deemed unexpected or sudden, as the prior commotion had already put the people in the house on guard. The means employed did not insulate the appellant from any risk from the victims, a requisite for treachery. Evident premeditation was also found to be absent, as the appellant’s actions were impulsive following the news of his son’s death.
Conversely, the Court recognized the presence of the mitigating circumstance of passion or obfuscation. The appellant, upon immediately learning of his son’s killing, acted under the influence of a powerful, natural impulse for vindication. This mitigating circumstance, without any aggravating circumstance to offset it, warranted a reduction of the penalty. Consequently, the crimes were properly classified as three separate homicides under Article 249 of the Revised Penal Code. Applying the Indeterminate Sentence Law, the Court imposed a penalty ranging from a minimum of 10 years and 1 day of prision mayor to a maximum of 14 years and 8 months of reclusion temporal for each homicide. The civil indemnities awarded by the trial court were affirmed.