G.R. No. L-4219
THE UNITED STATES, plaintiff-appellee, vs. ENRIQUE POSOC, ET AL., defendants-appellants.
April 1, 1908

FACTS:
The defendants were charged with the crime of asesinato (murder). The trial court acquitted Domingo Posoc, Melchor Posoc, and Anacleto Bonillo, but convicted Enrique Posoc, Regino Posoc, and three others. Enrique and Regino were sentenced to cadena perpetua, and the other three to twenty years’ imprisonment.

The deceased, Delfin Villa, 24 years old, died on June 8, 1907, in Zarraga, Iloilo. The motive for the crime was the alleged illicit relations between Villa and Consolacion Panabe, wife of Enrique Posoc.

The prosecution alleged that Villa was attacked by all eight defendants at dusk outside his house. Regino Posoc held Villa by the wrist while striking him with a bolo, and the other seven defendants then joined, showering blows upon him. Villa, despite numerous wounds, allegedly escaped, made his way to a door at the northeast corner of the house, entered, and then crossed the length of the building to a door on the west side, where he eventually died. The assailants pursued him and threatened to burn the house.

Enrique Posoc, however, claimed sole responsibility for the killing. He testified that he returned home, learned his wife was at Villa’s house, and, having suspected their illicit relations, went to Villa’s house. He looked through a door and discovered Villa and Consolacion “in flagrante delicto” (in the act of committing the crime). Enraged, he immediately attacked Villa with a bolo. Villa offered some resistance but was overcome and died at the spot where his body was found. Enrique’s wife escaped and disappeared.

The justice of the peace investigated the scene the morning after and found blood splashes at the foot of the stairs (where the prosecution alleged the initial attack), and a trail of blood leading around the outside of the house to the door at the northeast corner. Bloodstains were also found on and just inside this door. Crucially, there were no traces of blood between this northeast door and the spot where Villa’s corpse was found near the west door, nor outside the west door. The deceased had twenty-one bolo cuts, mostly on his left arm, hand, head, and shoulders. The court found it difficult to reconcile the absence of a blood trail inside the house and the concentrated nature of the wounds with the prosecution’s story of eight assailants attacking simultaneously.

ISSUE:
Whether the guilt of the accused, particularly for the crime of asesinato, was proven beyond a reasonable doubt, considering the conflicting testimonies and the inconsistencies with the physical evidence at the crime scene. Specifically, what offense, if any, Enrique Posoc committed given his admission.

RULING:
The Supreme Court reversed the conviction and sentence of all defendants (except Enrique Posoc). The Court found that the irreconcilable conflict in testimony, coupled with significant inconsistencies in the physical evidence (most notably the “break in the trail of blood” and the nature of the wounds), created a reasonable doubt as to the truth of the prosecution’s narrative. Therefore, all defendants, except Enrique Posoc, were acquitted of asesinato and ordered to be set at liberty.

As for Enrique Posoc, while he admitted slaying Delfin Villa, the Court was unwilling to accept the prosecution’s testimony contradicting his exculpatory explanation. The Court accepted Enrique’s defense that he surprised Villa and his wife in flagrante delicto. Consequently, Enrique Posoc was found guilty of the offense defined and penalized in Article 423 of the Penal Code (killing in a moment of fury upon surprising a spouse in flagrante delicto). He was sentenced to the penalty of destierro (banishment) for a period of two years, four months, and one day, forbidden to return to the municipality of Zarraga, Iloilo, or go to any place within 25 kilometers of that municipality. He was also ordered to pay his proportionate share of the costs in the court below.