People v. Intino
REITERATIONFacts
The Antecedents: The accused-appellant, Marianito Intino, was charged with Murder for allegedly attacking and killing Bienvenido Caluser with a bolo on September 17, 1976. The prosecution presented evidence that the appellant and the victim were drinking tuba at the house of Norma Calipayan. While the victim was seated with his back to the porch, the appellant suddenly rose, approached him from behind, and stabbed him. The victim was subsequently stabbed again by the appellant. The victim was brought to the hospital where he died later that night. Procedural History: The trial court found the accused Marianito Intino guilty beyond reasonable doubt of Murder and sentenced him to suffer the penalty of reclusion perpetua, with accessory penalties, and to pay P12,000.00 as compensation to the heirs of the victim. The Petition: The accused appealed the decision, assigning errors concerning the trial court's failure to consider the dying declaration of the deceased, its finding of guilt beyond reasonable doubt, and its finding that treachery attended the commission of the crime.
Issue(s)
Whether the trial court erred in not giving due weight to the dying declaration of the deceased. Whether the trial court erred in finding the appellant guilty of murder beyond reasonable doubt, considering the eyewitness testimonies and the appellant's actions after the incident. Whether treachery attended the commission of the crime, qualifying it as murder.
Ruling
The Supreme Court affirmed the decision of the trial court, finding the accused Marianito Intino guilty beyond reasonable doubt of the crime of Murder. The penalty imposed was modified based on the abolition of the death penalty and the Indeterminate Sentence Law.
Ratio Decidendi
On the issue of the dying declaration: The Supreme Court held that while the victim may have made a statement inside the bus identifying "Pare Benny" as his attacker, this dying declaration could not be given probative value. The Court reasoned that the victim was stabbed from behind and was in a weakened state, making it difficult for him to fully identify his assailant. Furthermore, the victim and the appellant had no prior quarrel, leading the victim to possibly name someone else he had been drinking with earlier as his attacker. The Court emphasized that the dying declaration was contradicted by the positive identification of the appellant by eyewitnesses Norma and Rosario Calipayan. On the issue of guilt beyond reasonable doubt: The Supreme Court found that the appellant was positively identified by eyewitnesses Norma and Rosario Calipayan, whose testimonies were consistent and credible. The Court noted that these witnesses had no motive to falsely implicate the appellant, who was a relative. The medical certificate, which described the fatal wound as entering from the posterior lumbar area and exiting the epigastric area, corroborated Norma Calipayan's testimony that the assailant approached the victim from behind. The Court also considered that the appellant fled the scene immediately after the incident, while the other suspect, Benny Relente, did not. On the issue of treachery: The Court concluded that treachery was present because the attack from behind was sudden and unexpected, leaving the victim defenseless and unable to defend himself, thus qualifying the crime as murder.
Main Doctrine
The Supreme Court affirmed the conviction of the accused for murder, holding that treachery was present as the attack was sudden and from behind, rendering the victim helpless. The Court also gave more weight to the positive identification by eyewitnesses over the dying declaration which was deemed unreliable due to the victim's condition and the possibility of misidentification.