People v. Laredo
REITERATIONFacts
The Antecedents: On May 13, 1981, in Sitio Mangat, Barangay San Pedro, Municipality of Rizal, Occidental Mindoro, four accused, Edilberto Laredo, Narciso Dalisay, Abelardo Luminate, and Wilfredo Luminate, were charged with two counts of Murder and one count of Frustrated Murder. The victims were Bernabe Balin, Wilky Rodas, and Rodelito Balin. The prosecution presented evidence that the accused stoned the victims' house and then attacked them with bladed weapons and stones. Bernabe Balin and Wilky Rodas died from their injuries, while Rodelito Balin sustained serious wounds but survived due to timely medical attendance. Jaime Carino testified that Bernabe Balin, before his death, identified some of the accused as his assailants. Procedural History: The Regional Trial Court of San Jose, Occidental Mindoro, Branch 45, found all four accused guilty of two counts of Murder and one count of Frustrated Murder. Accused-appellants Edilberto Laredo and Narciso Dalisay appealed their conviction. The brothers, Wilfredo and Abelardo Luminate, withdrew their appeal. The Petition: Accused-appellants Edilberto Laredo and Narciso Dalisay filed a joint brief, assailing the trial court's findings on the credibility of witnesses, the admissibility and weight of the dying declaration, the appreciation of treachery, conspiracy, and evident premeditation, and the rejection of their defenses of self-defense and alibi.
Issue(s)
Whether the trial court erred in holding that the testimony of the lone eyewitness, Rodelito Balin, is clear and convincing despite alleged contradictions. Whether the trial court erred in holding that the testimony of Jaime Carino corroborated Rodelito Balin's story and in admitting Bernabe Balin's dying declaration. Whether the trial court erred in holding that the crimes committed were murder and frustrated murder qualified by treachery, and that conspiracy and evident premeditation were proven. Whether the trial court erred in completely disregarding the version of the appellants, particularly the claim of self-defense by Edilberto Laredo and the alibi of Narciso Dalisay.
Ruling
The Supreme Court affirmed the judgment of the trial court with modifications regarding the indeterminate penalty for frustrated murder and the civil indemnity awarded. The Court ruled that the accused-appellants Edilberto Laredo and Narciso Dalisay are guilty beyond reasonable doubt of two counts of Murder and one count of Frustrated Murder.
Ratio Decidendi
On the credibility of Rodelito Balin's testimony: The Court found the contention that Rodelito Balin's testimony was not credible due to alleged contradictions to be without merit. The Court explained that affidavits, being taken ex-parte, are often incomplete and inaccurate, and minor discrepancies do not detract from the overall credibility of the witness. The alleged inconsistencies pointed out by the appellants were either not present in the record or pertained to minor details that did not affect the substance of Rodelito's testimony. The Court reiterated that it is a matter of judicial experience that affidavits are almost always incomplete and sometimes inaccurate, and that minor inconsistencies do not necessarily impair the credibility of the witness. On the admissibility and weight of Jaime Carino's testimony and Bernabe Balin's dying declaration: The Court found no inconsistency between Rodelito's testimony and Bernabe's dying declaration to Jaime Carino. The Court noted that Rodelito did not categorically state that Eding Luminate did not stab Bernabe, and Bernabe's statement included Peter, Beling, and Eding as responsible for his wounds. The Court also rejected the argument that Bernabe could not have made a dying declaration due to his fatal injuries, citing that he was able to reach Jaime Carino's house, ask for water, and only passed away an hour later. The Court emphasized that when a person is at the point of death, motives for falsehood are silenced, and statements made under such circumstances deserve great weight, making the dying declaration admissible. On the qualification of treachery, conspiracy, and evident premeditation: The Court held that treachery was present despite the initial stoning of the house. The Court reasoned that treachery exists when the offender employs means to insure execution without risk to himself, and the victims being told to raise their hands before the assault eliminated any defense they might have offered. The Court found that conspiracy was shown by the concerted efforts of the accused, their presence at the scene, and their simultaneous departure. Evident premeditation was also upheld, as there was sufficient time for the accused to plan the crime between 6:00 PM and 9:00 PM. On the defenses of self-defense and alibi: The Court rejected Edilberto Laredo's claim of self-defense, stating that the numerous and serious wounds inflicted on the victims indicated multiple assailants, not just one acting in self-defense. The Court also found it incredible that Laredo would not have sustained any injury if he were indeed assaulted by at least four men with handguns and bolos. For Narciso Dalisay, the Court found his defense of alibi unavailing against the positive identification by Rodelito Balin. The Court also gave credence to the police blotter entry regarding Dalisay's surrender and admission, presuming that official duty was regularly performed, and found no ill motive for the police officer to make a false entry.
Main Doctrine
The Supreme Court affirmed the conviction of accused-appellants for Murder and Frustrated Murder, holding that treachery was present despite the initial stoning, as the victims were made to raise their hands before the assault, insuring the execution without risk to the assailants. The Court also upheld the finding of conspiracy and evident premeditation, and rejected the defenses of self-defense and alibi due to lack of credible evidence and positive identification. The civil indemnity was increased, and the indeterminate penalty for frustrated murder was modified.