People v. Ulip
REITERATIONFacts
The Antecedents: On the night of May 24, 1949, Paulino Ulip, aged 72, was shot and killed while seated near the kitchen of his house. The assailant, Alfonso Bergonio, approached stealthily under cover of darkness and fired several shots with a carbine. Procedural History: After the incident, Andres Ulip was arrested and admitted to conspiring with Sotero Ulip and Alfonso Bergonio to kill the deceased. Bergonio confessed to the assassination, stating he was induced by Andres and Sotero Ulip due to their disgust with their father's stinginess and disposition. The two brothers also admitted their guilt in affidavits. Two informations were filed: one against Bergonio for murder, and another against Andres and Sotero Ulip for parricide. Bergonio pleaded guilty and was sentenced to cadena perpetua. Andres and Sotero Ulip pleaded not guilty, were tried, convicted, and appealed their sentence. The Appeal: The appellants, Sotero Ulip and Andres Ulip, appealed their conviction for parricide. The primary issue was whether they conspired with and induced Alfonso Bergonio to assassinate their father. The prosecution presented Bergonio's testimony, the confessions of the appellants, and the testimony of Sgt. Exequiel Martinez to establish their guilt.
Issue(s)
Whether the appellants, Sotero Ulip and Andres Ulip, conspired with and induced Alfonso Bergonio to commit parricide. Whether the confessions of the appellants were admissible as evidence, given their claims of duress and violence.
Ruling
The Supreme Court affirmed the conviction of Sotero Ulip and Andres Ulip for parricide. The Court found sufficient evidence to establish their conspiracy and induction of Alfonso Bergonio to kill their father. The penalty of life imprisonment was affirmed, and the indemnity was increased to P6,000.00.
Ratio Decidendi
On Whether the appellants conspired with and induced Alfonso Bergonio to commit parricide: The Court ruled in the affirmative. The testimony of Alfonso Bergonio, who was convicted of murder for the actual killing, substantially repeated his confession. He testified that Sotero Ulip gave him the carbine used in the killing, which Sotero had purchased with money contributed by Andres Ulip. Bergonio stated that Sotero instructed him to shoot their father, and he complied due to Sotero's suggestion and his own intoxication. Bergonio also reported the death to Andres Ulip afterward. Sergeant Exequiel Martinez corroborated that Andres and Sotero Ulip admitted their guilt as inducers, with Sotero stating he ordered Bergonio to kill their father because the old man was "very strict" and refused to give them their share of the lands. Martinez also found the carbine in Sotero's possession, who admitted buying it with money from Andres. The confessions of Sotero (Exhibit D) and Andres (Exhibit E) were also presented. Sotero's confession detailed the conspiracy, Andres' contribution of P100 for the rifle, and the subsequent acquisition and handover of the carbine to Bergonio. Andres' affidavit admitted giving the money for the carbine with the statement "sila ang bahala," which the Court interpreted as approval of their plan to kill Paulino Ulip. The Court considered Andres' admission, his failure to prevent the deed or denounce the conspirators, and Bergonio's immediate report of the death to him as proof of his conspiracy. His contribution of money for the weapon was deemed sufficient to make him a principal by cooperation. On Whether the confessions of the appellants were admissible as evidence: The Court ruled that the confessions were admissible. The trial judge rightly rejected the appellants' claims that Exhibits D and E were obtained through violence and threats. This rejection was based on their failure to identify the alleged torturers, their silence about the maltreatment to visiting relatives, and the positive assertion by the justice of the peace before whom they subscribed the affidavits that they did so voluntarily and freely, without duress. The Court also addressed the argument that proof of great ascendancy or influence is necessary for induction, stating that such proof is unnecessary when the principal actor admits being impelled by the advisor and acted pursuant to a prior plan or conspiracy, especially when coupled with a promise to condone indebtedness, as in this case. The Court found no reasonable doubt regarding the guilt of the prisoners, affirming their conviction.
Main Doctrine
The Supreme Court affirmed the conviction of the appellants for parricide, holding that conspiracy to commit the crime was sufficiently established. The Court found that the appellants, sons of the victim, conspired with Alfonso Bergonio to kill their father due to resentment over his stinginess and temper. The conspiracy was evidenced by their confessions, Bergonio's testimony, and Andres Ulip's contribution of money to purchase the murder weapon, making them principals by induction and cooperation. The Court also upheld the admissibility of the confessions, finding they were made voluntarily despite claims of duress.