People v. Adones
REITERATIONFacts
The Antecedents: On the evening of January 20, 1979, during a benefit dance in barangay Dilapa, Quezon, Bukidnon, a confrontation arose between Romeo Quioyo and Liberato Adones over a song request. Liberato Adones allegedly embraced Romeo Quioyo from behind, pinning his arms, and shouted to his son, David Adones, to stab the victim. David Adones then allegedly stabbed Romeo Quioyo with an icepick in the stomach, causing his death later that night. The incident happened suddenly, and the dance was initially allowed to continue until the victim's brother informed the organizers of the stabbing. Procedural History: The Court of First Instance of Bukidnon found Liberato Adones and David Adones guilty beyond reasonable doubt of murder, sentencing each to reclusion perpetua and ordering them to indemnify the heirs of the deceased. The accused appealed the decision. The Petition: The accused-appellants questioned the trial court's findings of fact, particularly regarding conspiracy, the credibility of witnesses, and the denial of their defenses of self-defense and lack of participation.
Issue(s)
Whether the trial court erred in finding accused-appellants Liberato Adones and David Adones guilty of murder. Whether accused-appellant David Adones acted in self-defense. Whether accused-appellant Liberato Adones acted in concert with his son, David Adones, in the killing of Romeo Quioyo; and whether the trial court erred in its appreciation of the evidence and credibility of witnesses. Whether the flight of the accused indicated guilt; and whether the form of the decision was proper.
Ruling
The appealed judgment of the trial court finding the accused-appellants guilty of murder is affirmed, with an increase in the indemnity to P30,000.00.
Ratio Decidendi
On the guilt of Liberato Adones and conspiracy: The Court affirmed the trial court's finding that Liberato Adones participated in the killing. Eyewitnesses Leonito Blancia and Basilio Abeto positively identified both Liberato and David Adones as the assailants. Blancia testified that Liberato embraced the deceased from behind, pinning his arms, and ordered David to stab him. This narration was corroborated by Abeto. The Court found no motive for the prosecution witnesses to falsely accuse the appellants, especially with such a grave offense. The well-lit dance hall further ensured the accuracy of the identification. The Court rejected Liberato Adones' defense and alibi, considering his positive identification as a direct participant in the crime. The sudden and unexpected stabbing of Romeo Quioyo while being held by Liberato insured the killing without risk to the assailants, thus establishing treachery. On the defense of self-defense of David Adones: The Court rejected David Adones' plea of self-defense. The burden of proof rests upon the accused who admits killing a person to establish all facts necessary to prove circumstances of self-defense, which David Adones failed to do. His version of the stabbing was found inherently unbelievable. He claimed not to know the deceased, yet he allegedly asked the victim where he was going, and the victim responded by questioning if David was taking sides. This was deemed incredible, as David's alleged prior interaction with the victim (kicking him) was not known to the victim. Furthermore, the physician who attended to the victim did not mention any signs of drunkenness, contrary to David's claim. On the concert of action, credibility of witnesses and alleged inconsistencies: The Court reiterated the well-settled rule that the findings of fact of the trial court on the credibility of witnesses are generally accorded the highest respect by the appellate court. The alleged inconsistencies in the testimonies of prosecution witnesses Leonito Blancia and Basilio Abeto were deemed minor and did not discredit their core testimonies. Blancia's seemingly incoherent answers were attributed to his misunderstanding of the questions, and his later testimony clearly identified the appellants and the manner of the crime. Abeto's discrepancy regarding the song request that initiated the trouble did not negate his presence at the scene or his witnessing of the criminal act. The Court also noted that the defense witnesses, including the barangay captain and chairman of the dance, did not witness the actual stabbing and only became aware of a disturbance later. Their testimonies were also considered less credible as they did not volunteer their version to the police until summoned. On the flight of the accused and the form of the decision: The Court agreed with the lower court that the actuations of the accused after the incident clearly pointed to their guilt. They attempted to flee and disposed of the icepick during their flight. The Court stated that the flight of the accused is not in accord with that of innocent men, further supporting their conviction. The Court found no merit in the assignment of error questioning the form of the decision. Citing People v. Sabijon, the Court held that when a decision narrates the substance of testimonies and declares that the defense has not been established, it amounts to an acceptance of the facts narrated by the prosecution witnesses, thus satisfying the constitutional requirement for stating the facts and law upon which the decision is based.
Main Doctrine
The defense of self-defense must be established by clear and convincing evidence. Flight of the accused after the incident is indicative of guilt. The findings of fact of the trial court on the credibility of witnesses are generally accorded the highest respect by the appellate court.