G.R. No. L-9593-94; July 31, 1957.
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ILDEFONSO PALO alias PONCIANO-PONCHING, and PEDRO PALO, defendants-appellants.

FACTS

In two consolidated criminal cases from Batangas, defendants-appellants Ildefonso Palo and his brother Pedro Palo were charged with the murder of their brother-in-law, Candido Catapang (Criminal Case No. 1061), and Ildefonso was separately charged with illegal possession of a firearm (Criminal Case No. 1062). After a joint trial, both were convicted. The trial court sentenced each to life imprisonment for murder, with indemnity to the heirs, and Ildefonso to an additional prison term for illegal possession.
The prosecution evidence, from eyewitnesses including the victim’s daughter Angeles Catapang, Santiago de Roxas, and Jose Navarro, established that on June 20, 1954, Candido Catapang had an altercation with his brother-in-law Juanito Palo at a river in Taal, Batangas. After Candido chased his daughter away, two shots were fired. Ildefonso Palo then emerged from behind boulders holding a pistol, and Pedro Palo immediately followed, slashing Candido across the face with a bolo. Candido died while being transported to the hospital.
The defense presented a different version, claiming Ildefonso intervened when Candido, allegedly drunk, was beating his daughter. They asserted that Candido attacked Ildefonso with a pistol, Ildefonso wrestled it away, and after firing a warning shot and then hitting Candido, he transferred the gun to his left hand and hacked Candido with a bolo when he kept advancing, thereby attempting to explain the facial wound attributed by the prosecution to Pedro. The trial judge found the defense version improbable for several reasons, including the illogical sequence of events (e.g., Candido sheathing his bolo to use a pistol against an unarmed man, then pursuing the man who now had the pistol, and Ildefonso opting to use a bolo while holding a firearm).
Key evidence against the defendants included Ildefonso’s sworn affidavit (Exhibit C) the day after the shooting, which corroborated the prosecution’s account and admitted his ownership of the unlicensed pistol. Furthermore, the defendants had attempted to settle the case by offering P3,500 as indemnity to the heirs, which was considered as an implied admission of guilt.

ISSUE

Whether the trial court correctly convicted the defendants-appellants of murder and Ildefonso Palo of illegal possession of a firearm based on the evidence presented.

RULING

Yes, the judgment is affirmed in toto. The Supreme Court upheld the convictions.
The Court found the prosecution’s evidence, provided by disinterested eyewitnesses, to be credible and sufficient to establish guilt beyond reasonable doubt. The defense’s version was deemed incredible and properly rejected by the trial judge. Ildefonso’s extrajudicial confession (Exhibit C) and the offer of compromise by the defendants provided further evidence against them. The killing was qualified by treachery. The mitigating circumstance of voluntary surrender was not sufficiently proven and was offset by the aggravating circumstance of relationship (the victim being the offenders’ brother-in-law). Thus, the penalty of life imprisonment for murder was appropriate. For illegal possession of the firearm used in the killing, the penalty imposed on Ildefonso was within the limits prescribed by law.