People v. Rillorta
REITERATIONFacts
The Antecedents: On May 7, 1979, at midnight, Barangay Captain Emiliano Doton was found dead in a creek with multiple hack wounds. Inquiries led to the Rillorta family. Pascual Baylon Rillorta surrendered a bolo, and another was found in their house. Pascual's son, Wesley, confessed to hacking the victim. A witness, Romy Ramos, testified that Pascual Rillorta threatened him and later, along with his sons Wesley and Wilson, accosted Ramos' threshing party. When Barangay Captain Doton intervened to let the threshing party pass, the Rillortas chased and attacked him, pushing him into a creek and hacking him. Dr. Bienvenido Allas autopsied the victim, finding thirty-two bolo wounds. Pascual Rillorta claimed self-defense, stating Doton attacked him first. Wesley Rillorta claimed he was defending his father. Wilson Rillorta presented an alibi, claiming he was in Tayug for tire vulcanization. Procedural History: The Court of First Instance of Pangasinan, Branch VI, found Pascual Baylon Rillorta and Wesley Rillorta guilty as principals and Wilson Rillorta as an accomplice in the complex crime of direct assault with murder. They were sentenced accordingly, and ordered to indemnify the heirs of the victim. The Petition: The accused appealed the decision, alleging errors in the trial court's findings regarding treachery, the victim's official capacity, motive, legitimate defense, Wilson's participation, self-inflicted wounds, and the weight given to prosecution witnesses.
Issue(s)
Whether the killing of Barangay Captain Emiliano Doton was attended by treachery, warranting a charge of murder instead of homicide. Whether the deceased was performing his official duties as barangay captain when attacked, and whether Pascual Rillorta's resentment was the motive for the killing. Whether Wesley Rillorta acted in legitimate defense of his father, Pascual Rillorta. Whether Wilson Rillorta had knowledge or participation in the murder, considering his alibi. Whether the finger wounds of Pascual Rillorta were self-inflicted or inflicted by Wesley during the attack. Whether the trial court erred in giving more credit to prosecution witnesses over defense witnesses, considering the consistency and support of physical evidence. Whether the crime should be classified as direct assault with murder or a complex crime of homicide with assault upon a person in authority.
Ruling
The Supreme Court modified the decision, finding the accused guilty of the complex crime of homicide with assault upon a person in authority, not direct assault with murder. Pascual Baylon Rillorta and Wesley Rillorta were declared guilty as principals, and Wilson Rillorta as an accomplice. They were each sentenced to an indeterminate penalty ranging from twelve (12) years of prision mayor, as minimum, to twenty (20) years of reclusion temporal, as maximum. They were ordered to jointly and severally indemnify the heirs of the deceased Emiliano Doton in the amount of P30,000.00 for his death, plus P5,350.00 for funeral expenses, and to pay one-third (1/3) of the costs.
Ratio Decidendi
On the issue of treachery: The Court ruled that the assault upon the deceased was not attended by treachery because it was preceded by a heated exchange of words between the appellants and the deceased. Treachery requires that the victim be caught completely by surprise, which was not the case here as there was a prior confrontation. Therefore, the killing was classified as homicide, not murder, under Article 249 of the Revised Penal Code. The Court cited People vs. Ibanez, People vs. Quiban, and People vs. Visagar in support of this finding. On the victim's official capacity and motive: The Court affirmed that the deceased was performing his official duties as barangay captain when attacked. Doton intervened to prevent a violent encounter between the accused and the threshing party, which falls under his duty to protect life and property and enforce law and order. The Court clarified that Doton had no financial interest in the threshing party's work, as it was Mrs. Soriano who invited them. Pascual Rillorta admitted his resentment towards Doton for hiring another thresher, which motivated the assault. This resentment was expressed when Pascual accosted the threshing party and warned them not to return. On legitimate defense of self or relative: The Court rejected Wesley Rillorta's plea of legitimate defense. It found that the deceased had not committed any unlawful aggression against Pascual Rillorta. The testimonies of eyewitnesses and the nature of the victim's wounds indicated that the appellants were the aggressors. Dr. Allas' autopsy report revealed 32 wounds inflicted by two or more persons, supporting the prosecution's claim that the Rillortas initiated the attack. Prosecution witness Ceferino Facon also declared that the appellants were the aggressors. On Wilson Rillorta's participation and alibi: Wilson Rillorta's alibi was found unconvincing. He claimed to be in Tayug for tire vulcanization from 8:00 p.m. to 11:00 p.m. on the night of the incident. However, the travel time between Tayug and Barangobong was only forty minutes. This meant it was physically possible for him to have returned to Barangobong by 10:00 p.m., when the killing occurred. His alibi could not prevail over the positive identification by prosecution witness Ceferino Facon, who testified that Wilson assisted in the killing by holding the victim's hands while Pascual hacked him. The Court noted that the witness identified all three Rillortas in court. On the nature of the wounds: The Court dismissed the contention that Pascual Rillorta's finger wounds proved he was attacked. The prosecution witness Facon stated that the deceased's hands were held by Wesley and Wilson while Pascual inflicted the wounds. Therefore, Pascual's injury was likely self-inflicted or inflicted by Wesley during the attack. On the credibility of witnesses: The Court found no error in giving more credit to the prosecution witnesses, whose testimonies were consistent and supported by physical evidence, over the defense witnesses, whose accounts were either unconvincing or contradicted by the evidence. On the issue of treachery: The absence of treachery meant that the crime could not be direct assault with murder, but rather a complex crime of homicide with assault upon a person in authority.
Main Doctrine
The crime of direct assault with murder, when committed by multiple persons, and involving the killing of a person in authority while discharging his duties, is a complex crime. The presence of treachery is negated by a prior heated exchange of words, reducing the crime to homicide with assault upon a person in authority. Legitimate defense requires unlawful aggression, which was absent in this case. An alibi must be substantiated and cannot prevail over positive identification.