People v. Aquiatan
REITERATIONFacts
The Antecedents: On April 13, 1968, at approximately 7:00 PM, Simplicio Abayon, a police officer, hired a Honda scooter. He went to Barrio Burabod and later met with co-accused Alfonso Aquiatan and Jaime Limpiado, also police officers. While returning to the poblacion, Abayon made a statement indicating an intent to harm Aquillano Rodrigo. Upon reaching Sitio Pongdol, they inquired about Rodrigo's house and proceeded to the house of Melanio Gallardo where Rodrigo was. The policemen barged in, and Aquiatan ordered no one to run. Limpiado and Abayon held Rodrigo's wrists and raised them. Abayon then instructed Aquiatan to shoot Rodrigo, stating they had instructions from the Mayor. Aquiatan shot Rodrigo, who died the following day from the gunshot wound. Procedural History: The Court of First Instance of Northern Samar found Alfonso Aquiatan and Simplicio Abayon guilty of Murder, sentencing them to reclusion perpetua and ordering them to indemnify the heirs of the victim. Jaime Limpiado was acquitted due to reasonable doubt. Aquiatan and Abayon appealed. Aquiatan later withdrew his appeal. The Petition: Simplicio Abayon appealed his conviction.
Issue(s)
Whether conspiracy was sufficiently established. Whether the accused acted in self-defense. Whether the trial court erred in its appreciation of the evidence and credibility of witnesses.
Ruling
The Supreme Court affirmed the judgment of the trial court, finding Simplicio Abayon guilty of Murder, with the modification that he be credited with the full time of his preventive imprisonment. The conviction of Alfonso Aquiatan was also affirmed as he had withdrawn his appeal.
Ratio Decidendi
On the issue of conspiracy: The Court held that conspiracy was sufficiently established by the concerted actions of the accused. The evidence showed that the accused were together in going to Sitio Pongdol to confront the deceased. Simplicio Abayon's statement en route indicated a common design. The act of Alfonso Aquiatan ordering the deceased and his companions not to run, followed by Jaime Limpiado and Simplicio Abayon holding the deceased's hands and raising them, and Abayon's instruction to Aquiatan to shoot, demonstrated a common purpose and design to commit the crime. This collective action proved conspiracy, making Abayon equally liable with Aquiatan. On the issue of self-defense: The Court rejected the claim of self-defense. While there was an initial unlawful aggression by the deceased earlier that afternoon when he challenged Aquiatan's authority and boxed him, this aggression had ceased when Aquiatan did not pursue the deceased but instead sought help from the barrio captain and waited for reinforcements. For self-defense to be appreciated, the aggression must be continuous and unlawful. The deceased's earlier act of aggression did not constitute an ongoing threat that would warrant self-defense at the time of the shooting, especially given the circumstances where the deceased's hands were raised by the co-accused. On the issue of credibility of witnesses: The Court found no overriding consideration to reverse the trial court's findings on the credibility of witnesses. It reiterated the well-settled principle that the Supreme Court respects the findings of fact of the trial judge who had the opportunity to weigh and appraise the testimony. The appellant's imputations of bias against the prosecution witnesses were deemed unfounded conclusions based merely on assumptions. The Court found the testimony of Melanio Gallardo to be categorical and consistent with the established facts.
Main Doctrine
The Supreme Court affirmed the conviction of the accused for murder, holding that conspiracy was sufficiently established by the concerted actions of the accused, and that the claim of self-defense was untenable due to the cessation of unlawful aggression. The Court also reiterated its respect for the findings of fact of the trial court regarding witness credibility.