People v. Quijano
REITERATIONFacts
The Antecedents: On September 16, 1986, at around 11:00 PM, in Carcar, Cebu, Abundio Baring and his wife Quintina were awakened by Elanito Quijano's call for water. As Abundio went to fetch water, he was stabbed by Edgar Gonzales, while Edwin Layog and Elanito Quijano held him. Quintina Baring, who witnessed the stabbing, was prevented from shouting for help by Danilo Lapinid. Abundio Baring sustained multiple stab wounds, causing his instantaneous death. Edgar Gonzales then beheaded the victim in the presence of the other accused, placed the head in a sack, and they left for Mandaue. Later that morning, Pat. Joseph Togonon intercepted the four accused in Mandaue City and found the victim's head in their possession. In Carcar, the headless body of Abundio Baring was found. The Municipal Health Officer's examination revealed 13 stab wounds. Procedural History: The accused-appellants were found guilty beyond reasonable doubt as co-principals of murder by the Regional Trial Court, Branch 16 at Cebu City, and were sentenced to suffer the penalty of reclusion perpetua. They appealed the decision. The Petition: The accused-appellants faulted the trial court for giving credence to the testimonies of prosecution witnesses, for giving weight to the extrajudicial confessions of Layog and Lapinid, for finding conspiracy among them, for disregarding their testimonies, and for convicting them.
Issue(s)
Whether the trial court erred in giving credence to the testimonies of the prosecution witnesses. Whether the trial court erred in giving weight to the extrajudicial confessions of Edwin Layog and Danilo Lapinid. Whether there was conspiracy among the accused. Whether the accused-appellants were correctly convicted of murder.
Ruling
The appealed decision is hereby AFFIRMED with the modification that the indemnity to be paid by appellants should be increased to fifty thousand pesos (P50,000.00).
Ratio Decidendi
On the credibility of prosecution witnesses: The Court found the testimony of Quintina Vda. de Baring credible, as she was present during the killing and identified the accused and their roles. The Court noted that there was no reason for her to fabricate evidence against the appellants. Her testimony was corroborated by Pat. Togonon, who intercepted the appellants with the victim's head and to whom they readily acknowledged culpability. The Court also found the testimonies of Pat. Togonon and Pat. Panaganan credible. On the validity of extrajudicial confessions: The Court found the extrajudicial confessions of Layog and Lapinid to be valid. Both confessions were executed with the assistance of their respective lawyers, as evidenced by the signatures of the assisting counsels. The Court dismissed the appellants' claims of force and intimidation as unsubstantiated and a mere attempt to backtrack from their voluntary admissions of guilt. The regularity and legality of the confessions were upheld. On the existence of conspiracy: The Court found that conspiracy was sufficiently established. The extrajudicial confessions of Layog and Lapinid indicated that they hatched the plan to kill Abundio Baring, with Quijano initiating the idea due to a perceived slight and Gonzales proposing the beheading to threaten his former employer. The widow's testimony identified the accused as mutually helping each other in the killing. Furthermore, the accused, still together, took the victim's head to Mandaue, demonstrating a unity of purpose from planning to the disposal of the crime's effects. The Court reiterated that in conspiracy, the act of one is the act of all. On the conviction of the accused: Based on the established conspiracy, the credible testimonies of the witnesses, and the valid extrajudicial confessions, the Court affirmed the conviction of the accused-appellants for murder. The Court found that the prosecution had competently and sufficiently established the fact of the killing and the participation of all the accused in a manner that constituted murder, with the aggravating circumstances of treachery and evident premeditation as alleged in the information. The Court emphasized that the defense failed to present evidence that could overcome the probative force of the People's evidence.
Main Doctrine
Conspiracy is established by unity of action and purpose, where the act of one is the act of all. Extrajudicial confessions made with the assistance of counsel are presumed valid and regular, and allegations of force or intimidation must be substantiated by evidence.