G.R. No. L-40118 May 22, 1985
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. IGNACIO PANUELOS y ZIGA, DAVID PANUELOS y ZIGA, ISIDRO PANUELOS y ZIGA, RODOLFO PANUELOS y RAMOS, and FRANCISCO PANUELOS, accused, IGNACIO PANUELOS y ZIGA and RODOLFO PANUELOS y RAMOS, accused-appellants.

FACTS

On March 25, 1970, Municipal Judge Florentino Pan, Jr., together with companions, went to harvest palay in Barrio Bagacay, San Jose, Camarines Sur. A group of armed men led by Ignacio Panuelos arrived. Ignacio confronted the judge, angrily questioning why he was harvesting the crop, which Ignacio claimed as his own. After a brief exchange, David Panuelos held the judge’s arm. Prompted by a shout from the group, David then struck the judge’s face with a bolo. Isidro Panuelos followed, hitting the victim on the head, and Rodolfo Panuelos struck him with a piece of wood. Ignacio then hacked the judge on the shoulder. The assault ceased only when a companion stated the victim was already dead. The autopsy revealed thirty-one incised wounds. The prosecution presented extra-judicial confessions taken on March 26, 1970. The trial court convicted Ignacio, David, and Isidro Panuelos of murder, imposing the death penalty. Rodolfo was sentenced to life imprisonment, and Francisco was acquitted. The case is on automatic review for the death penalty convicts.
The appellants claimed self-defense, alleging Judge Pan attacked Ignacio first with a scythe and a gun. They asserted that only Ignacio assaulted the judge and that their confessions were inadmissible. The defense narrative posited that the judge was the initial aggressor in a dispute over the tenancy and harvest of the ricefield.

ISSUE

The primary issue is whether the trial court correctly convicted the appellants of murder, qualified by treachery and evident premeditation, and properly admitted their extra-judicial confessions.

RULING

The Supreme Court affirmed the conviction but reduced the penalty. The claim of self-defense was untenable. The evidence established conspiracy, as the appellants arrived together, armed, and collectively assaulted the unarmed victim, inflicting numerous wounds while sustaining none themselves. The trial court correctly found evident premeditation, as Ignacio had nursed a grudge since the judge tractored his crop a year prior, planning retaliation instead of seeking judicial recourse. Treachery was present but was absorbed by the qualifying circumstance of evident premeditation. Regarding the confessions, the Court ruled them admissible. They were obtained in 1970, prior to the effectivity of the 1973 Constitution, which mandated the right to counsel during custodial investigation. Applying Magtoto vs. Manguerra, the constitutional exclusionary rule did not apply retroactively. Consequently, the conviction for murder was upheld. However, due to the lack of necessary votes for the death penalty, the sentence for Ignacio Panuelos was reduced to reclusion perpetua, and the indemnity was increased to P30,000.00. The judgment was affirmed in all other respects.