People v. Masangkay
REVERSALFacts
The Antecedents: On July 21, 1981, at around 10:30 PM, Ely Verano was attacked and stabbed to death at the market site in Masbate, Masbate. His son, Arthur Verano, witnessed Amador Masangkay stab his father while Carlito Mirano covered the victim's mouth and Jaime Masangkay held his hands behind his back. Arthur shouted at the assailants, prompting Amador to tell his companions to flee. Jaime and Carlito then chased Arthur. Osita Castillo, a neighbor, heard shouts for help and saw Amador bending over the victim. She intervened and saw Amador holding a bladed weapon. Ely Verano, before being brought to the hospital, told his wife, Feligonia Verano, that he was stabbed by Amador, held by Jaime, and had his mouth covered by Carlito. Ely Verano died shortly after arriving at the hospital due to severe hemorrhage from multiple stab wounds. Procedural History: The Regional Trial Court of Masbate convicted Amador Masangkay, Jaime Masangkay, and Carlito Mirano of murder, sentencing them to reclusion perpetua and ordering them to pay indemnity to the heirs of the victim. The Petition: The accused appealed the decision of the Regional Trial Court. The Supreme Court, in its Resolution, denied the motion for reconsideration for acquittal but amended the decision regarding the penalty.
Issue(s)
Whether the testimonies of the deceased's son and widow were credible despite alleged inconsistencies. Whether Feligonia Verano's revelations about her discussion with her husband formed part of the res gestae or were dying declarations. Whether the trial court erred in giving credence to Feligonia's testimony. Whether conspiracy existed among the accused. Whether Amador Masangkay acted in self-defense. Whether bias was present in the testimonies of Arthur and Feligonia Verano.
Ruling
The Supreme Court affirmed the conviction of Amador Masangkay, Jaime Masangkay, and Carlito Mirano for murder. The penalty was modified to an indeterminate sentence of ten (10) years and one (1) day of prision mayor, as minimum, to eighteen (18) years, eight (8) months and one (1) day of reclusion temporal, as maximum. The indemnity to the heirs of the victim was maintained at P30,000.00.
Ratio Decidendi
On the credibility of witnesses and alleged inconsistencies: The Court found no reason to doubt the testimony of Arthur Verano, the eyewitness, who clearly identified the appellants ganging up on his father. The Court also found corroboration in the testimony of Osita Castillo. The relationship of mother and son between Feligonia and Arthur Verano did not militate against their credibility. The alleged inconsistencies were deemed minor or explained by the circumstances. On whether Feligonia Verano's revelations constituted res gestae: The Court held that the victim's statements to his wife identifying his assailants and the manner of their participation, made within an hour after the stabbing and while he was being transferred to the hospital, formed part of the res gestae. These statements were made under circumstances where the victim had no time to contrive or falsify, thus being competent testimonial evidence. The Court cited Section 36, Rule 130 of the Rules of Court and the case of People vs. de Gracia. On the trial court's credence to Feligonia's testimony: The Court found no error in the trial court giving credence to Feligonia's testimony, especially since it was corroborated by other evidence and the victim's statements were admissible as part of the res gestae. The Court noted that even without Feligonia's testimony, the eyewitness accounts of Arthur Verano and Osita Castillo were sufficient to sustain the conviction. On the existence of conspiracy: The Court affirmed the trial court's finding of conspiracy. It reasoned that conspiracy exists when participants have the same purpose and are united in its execution, which can be inferred from attendant circumstances. The coordinated actions of Jaime holding the victim's hands and Carlito covering his mouth while Amador stabbed the victim demonstrated a community of criminal purpose and the taking advantage of superior strength. The act of one conspirator was deemed the act of all. On Amador Masangkay's claim of self-defense: The Court sustained the trial court in rejecting Amador's claim of self-defense. Having admitted the killing, the burden was on Amador to prove self-defense by clear and convincing evidence, which he failed to do. The number, location, and depth of the stab wounds contradicted self-defense. Furthermore, the requisites of self-defense were absent; the victim's alleged threats and door-banging did not constitute unlawful aggression, and even if it did, the means employed by Amador were not reasonably necessary after disarming the victim. On bias in the testimonies of Arthur and Feligonia Verano: The Court found no bias in the testimonies of Arthur and Feligonia Verano. Their relationship to the deceased did not automatically discredit them, and their accounts were found to be credible and corroborated by other evidence. The Court also noted that Arthur's testimony was further supported by the fact that the police immediately looked for Amador after the incident, indicating his flight from the scene.
Main Doctrine
The Court affirmed the conviction for murder, modifying the penalty to an indeterminate sentence. It held that conspiracy was sufficiently established by the coordinated actions of the accused, and rejected claims of self-defense and alibi due to credible eyewitness testimony and physical evidence. The Court also affirmed that statements made by the victim shortly before death, identifying his assailants, constituted part of the res gestae.