People v. Pineda
REITERATIONFacts
The Antecedents: On February 4, 1946, Segundo Pineda, Francisco Pineda, Mamerto Cortes, Pedro Sicat, Cayetano Canlas, and Jesus Catacutan called Fernando Zita. After some persuasion, they proceeded to drink beer. They then inquired about the whereabouts of a woman who married Olegario Suarez, a municipal policeman. Guided by Zita, they proceeded to the house of Suarez's father-in-law. Mamerto Cortes and Francisco Pineda, armed with revolvers, entered the house while others guarded it. They ordered the occupants to raise their hands, and Cortes ordered Suarez to come down. Francisco Pineda threatened Suarez with death if he shouted. Jesus Catacutan tied Suarez's hands. Cortes inquired about Suarez's revolver from his wife. The accused then left with the bound Suarez towards barrio Sta. Barbara, questioning him about denouncing them to the military police. In barrio Sta. Barbara, Sicat and Catacutan ordered Serafin Ocampo to bring a shovel and his carbine and directed him to dig a hole. Suarez, sensing danger, untied himself and ran but was caught by Catacutan and Pineda and thrown into the hole. Cortes shot Suarez, and Sicat shot him in the back. Suarez died. Cortes and Sicat buried the body in the hole, ordering Ocampo to cover it. They then went to Ocampo's house, where he was compelled to give them food. Before leaving, they made Ocampo sign a paper and threatened to kill him if he revealed the incident. Procedural History: A complaint for murder was filed against Segundo Pineda, Francisco Pineda, Mamerto Cortes, Pedro Sicat, Cayetano Canlas, Jesus Catacutan, and Serafin Ocampo. The complaint was dismissed against Serafin Ocampo to be used as a government witness, against Segundo Pineda for insufficiency of evidence, and against Mamerto Cortes, Pedro Sicat, and Cayetano Canlas for not having been apprehended. Jesus Catacutan and Francisco Pineda were convicted by the trial court to reclusion perpetua, with accessories, to jointly and severally indemnify the heirs of Olegario Suarez in the amount of P2,000.00, without subsidiary imprisonment in case of insolvency, and to pay the costs. They appealed. The Petition: The appellants, Jesus Catacutan and Francisco Pineda, appealed their conviction.
Issue(s)
Whether the defense of alibi (coartada) is sufficient to exculpate the appellants in light of the testimony of the prosecution witnesses. Whether the appellants are entitled to the benefits of Amnesty Proclamation No. 76.
Ruling
The appealed decision is affirmed with costs. The appellants, Jesus Catacutan and Francisco Pineda, are found guilty of murder and sentenced to reclusion perpetua, with accessories, to jointly and severally indemnify the heirs of Olegario Suarez in the amount of P2,000.00, without subsidiary imprisonment in case of insolvency, and to pay the costs.
Ratio Decidendi
On Issue 1: The Court held that the defense of alibi (coartada) must be received with great caution because it is a piece of evidence that is fabricated with such ease that it deserves no credit. The Court found it suspicious that both appellants used the exact same excuse—that their mothers were gravely ill on the day of the crime—to explain their presence at home. The positive identification by witnesses Serafin Ocampo and Nicolas Ticsay carried more weight than the appellants' denials, especially since the witnesses had no significant motive to lie about such a grave crime. The Court noted that the trial judge's observation of the witnesses' demeanor during the trial is entitled to great respect and found no reason to alter the lower court's conclusion. Therefore, the alibi was rejected as a manufactured defense. On Issue 2: The Court ruled that the appellants are not entitled to the benefits of Amnesty Proclamation No. 76 for three distinct reasons. First, the amnesty is conditional and applies only to those who voluntarily presented themselves with all their arms and ammunition to the duly constituted authorities; here, the appellants were arrested and were already in prison (presos preventivos) when they sought the benefits. Second, both appellants had previously declared under oath during their trial that they were not members of the Hukbalahap or PKM, and such judicial admissions under oath prevail over the unsworn certificates of membership they later submitted. Third, the crime committed was not for a political or seditious purpose, as the victim was not performing his duties as a policeman at the time, and the motive for the killing was personal revenge for supposedly reporting the group to the military police. Thus, the requirements of the amnesty proclamation were not satisfied.
Main Doctrine
The defense of alibi must be received with great caution, as it is a defense that is easily fabricated and therefore not worthy of credit. Declarations made under oath prevail over mere certificates. To avail of amnesty, the accused must voluntarily surrender with their arms and ammunition, not claim it after apprehension.