People v. Labak
REITERATIONFacts
The Antecedents: The accused Yakan Labak, Yakan Abdula, Yakan Amang, Yakan Buslot, and Yakan Iman Maalim were charged with the murder of Jose Atilano. The victim, Jose Atilano, the general manager of American Rubber Company, was shot and killed while traveling in a company jeep. The prosecution established that as the jeep proceeded on an incline, an armed man was seen on the roadside. As the armed man approached, passengers in the back of the jeep jumped out. Immediately thereafter, gunshots were heard, and Atilano cried out in pain. The victim sustained multiple gunshot wounds and an incised wound. Missing from the victim were his wrist watch and a package of medicine. Procedural History: The Court of First Instance of Basilan City acquitted Abdul for insufficiency of evidence but convicted the other five accused of murder. The court considered the aggravating circumstances of uninhabited place and by a band, offset by the mitigating circumstance of lack of instruction, and sentenced each to life imprisonment, with civil indemnity and costs. The Petition: The convicted accused appealed the decision.
Issue(s)
Whether the prosecution failed to clearly prove the motive for the murder. Whether the extrajudicial confessions of the appellants are admissible in evidence. Whether the guilt of the appellants was proven beyond reasonable doubt. Whether the aggravating circumstances of uninhabited place and by a band were correctly considered. Whether the mitigating circumstance of lack of instruction was correctly considered. Whether the civil indemnity should be modified.
Ruling
The appealed decision is affirmed, with modifications. The indemnity to the heirs is raised to P6,000.00. The conviction of Yakan Labak, Yakan Abdula, Yakan Amang, Yakan Buslot, and Yakan Iman Maalim for murder is upheld.
Ratio Decidendi
On the motive for the murder: The Court found that the prosecution sufficiently established the motive. Iman Maalim's sworn statement revealed that he was promised P300.00 by Sandung and Mustaman to kill Atilano, and that he persuaded the other appellants to commit the murder for P200.00, with the remaining P100.00 as his reward. His fear of Sandung and Mustaman also served as a motive. The other appellants were impelled by motives of gain. The Court rejected the argument that the grudge should have been directed at Damaso Parugay, as the victim was the company manager and represented the company. On the admissibility of extrajudicial confessions: The Court rejected the appellants' claim of maltreatment and intimidation. Several reasons persuaded the Court: (1) No medical certificates were presented to support the claims of brutal maltreatment, and the alleged scars on Labak were insignificant. (2) The other appellants showed no indication of abuse. (3) It was more credible that maltreatment would occur upon refusal to confess, not before questioning. (4) There was no apparent motive for the PC soldiers to abuse the appellants, thus the presumption of regularity in the performance of their duties applied. (5) The appellants did not reveal the alleged maltreatment to Judge De Guzman when they swore to their confessions. (6) The acquitted Abdul's testimony of maltreatment was unconvincing as he only admitted to handing over a shotgun, not participating in the killing. On the proof of guilt beyond reasonable doubt: The Court found the guilt of the appellants proven beyond reasonable doubt. This was established by their extrajudicial confessions, corroborated by the testimony of three eyewitnesses (Jose Fermin, Jr., Manuel San Luis, and Estanislao Falcasantos) who identified Abdula as the triggerman. The eyewitnesses positively identified Abdula and picked him out from a group in court. San Luis and Falcasantos also identified Amang and Buslot. The recovery of the murder weapon and the barongs from Abdul, a relative of the appellants, further corroborated their participation. Labak's alibi was not convincing, and the other appellants did not present any defense to disprove their presence. On the aggravating circumstances of uninhabited place and by a band: The Court affirmed the lower court's action in considering these as only one aggravating circumstance. This is in line with established jurisprudence that when multiple aggravating circumstances are present, they may be treated as one if they arise from the same act or conduct, or if one is absorbed by another. The Court cited People v. Santos, et al., 91 Phil., 320, in support of this principle. On the mitigating circumstance of lack of instruction: The Court affirmed the lower court's consideration of lack of instruction as a mitigating circumstance. This is a recognized mitigating circumstance under the Revised Penal Code, acknowledging that individuals with limited education may have a diminished capacity to understand the gravity of their actions or the consequences thereof. On the modification of civil indemnity: The Court found it proper to increase the indemnity to the heirs of the victim from P3,000.00 to P6,000.00, aligning with prevailing jurisprudence on the amount of damages awarded in murder cases.
Main Doctrine
Conspiracy having been clearly established, the act of one is attributable to all. The lower court acted correctly in considering as only one aggravating circumstance an uninhabited place and by a band, but offset by the mitigating circumstance of lack of instruction.