G.R. No. L-8699 December 26, 1956
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. LORENZO RUZOL, ET. AL., defendants, LORENZO RUZOL, defendant-appellant.

FACTS

In the evening of August 5, 1954, Juan Andal and his family were asleep in their house in Sitio Calisetan, Baler, Quezon. His son, Eladio Andal (11 years old), was awakened by a sound like a coconut being cut. He saw appellant Lorenzo Ruzol standing beside his father. As Eladio moved, Ruzol walked to the kitchen. Eladio stood up, saw his father wounded, went to a window, opened it, and recognized Manuel Torres outside. Torres then joined Ruzol, and both ran towards Torres’s house. Eladio followed, shouting for help. He and a neighbor later reported the killing to the Philippine Constabulary, identifying Ruzol and Torres as the perpetrators. The Constabulary found Torres and Ruzol in their houses and brought them to see the deceased’s body, where both were observed to shudder. An autopsy revealed fatal incised wounds and skull fractures caused by a sharp, square-ended instrument like a hatchet. Eladio testified that a lamp illuminated the room, enabling him to recognize Ruzol (wearing a checkered shirt and denim pants) and Torres. Dominga Eugenio, who was sleeping in Torres’s house that night, corroborated that Torres and Ruzol left together and returned hours later, admitting they killed Juan Andal and telling her not to tell anyone. Evidence showed motive: an altercation earlier that day between the deceased and Torres over land, and Ruzol’s anger because the deceased had sent away his wife, who was allegedly Ruzol’s paramour. The accused denied the charges, claiming they never left their houses that night.

ISSUE

Whether the trial court correctly found Lorenzo Ruzol guilty of murder based on the evidence presented.

RULING

Yes, the Supreme Court affirmed the conviction but modified the penalty. The Court found the testimony of eyewitness Eladio Andal logical, straightforward, and credible, corroborated by Dominga Eugenio and circumstantial evidence (e.g., the altercation, the presence of a hatchet in Torres’s house, and the accused’s conduct when shown the body). The Court rejected the defense’s arguments, including the absence of bloodstains on Ruzol’s clothes, explaining that the victim’s position and wound direction made it unlikely for blood to besmirch the assailant. The crime was murder qualified by treachery. The trial court found three aggravating circumstances (dwelling, nighttime, and abuse of superior strength), but the Supreme Court, agreeing with the Solicitor General, held that nocturnity and abuse of superior strength are absorbed in treachery, while dwelling remains a separate aggravating circumstance. Due to lack of sufficient votes for the death penalty, the Court modified the sentence to reclusion perpetua. The judgment was affirmed in all other respects.