People v. Mancao
REITERATIONFacts
The Antecedents: On October 20, 1979, Artemio Pat and Lucy Lapira exchanged marriage vows. In the evening of the same day, while Artemio's group was walking home, they were waylaid and attacked by six appellants. Marcelina Pat was attacked by Fructuoso Mancao with a scythe and Benedicto Mancao with a bolo. Artemio Pat was simultaneously attacked by Joel "Tiboy" Mancao and the rest of the appellants using bolos, scythe, "chaco," and bow and arrow. Artemio Pat sustained multiple wounds and died. Marcelina Pat sustained hacked and incised wounds. Procedural History: The Regional Trial Court of Dumaguete City, Branch XXXII, rendered a joint decision finding Fructuoso Mancao and Benedicto Mancao guilty of Frustrated Murder in Criminal Case No. 3786, and all six appellants guilty of Murder in Criminal Case No. 3787. The trial court appreciated the mitigating circumstance of voluntary surrender in favor of Fructuoso Mancao. The Petition: The six appellants appealed the joint decision of the trial court.
Issue(s)
Whether the guilt of the accused-appellants for the crimes of Murder and Frustrated Murder was proven beyond reasonable doubt. Whether the defenses of self-defense and alibi were sufficiently established. Whether treachery was present in the commission of the crimes. Whether conspiracy was established among the accused-appellants. Whether the penalty imposed by the trial court was correct, particularly the application of the Indeterminate Sentence Law.
Ruling
The Supreme Court affirmed the decision of the Regional Trial Court with modification regarding the penalty imposed on Fructuoso Mancao. The Court increased the indemnity to the heirs of the deceased to P50,000.00. The Court found the accused-appellants guilty beyond reasonable doubt of Murder and Frustrated Murder.
Ratio Decidendi
On the guilt of the accused-appellants for Murder and Frustrated Murder: The Court found the prosecution's evidence more convincing than the defenses of alibi and self-defense. The positive testimonies of eyewitnesses Marcelina Pat and Melchor Isong, who positively identified the appellants as the assailants, were given full weight and credence. The Court noted that the defense of alibi is the weakest of all defenses and must be substantiated by evidence that it was physically impossible for the accused to have been at the scene of the crime. The Court also found that the nature and number of wounds sustained by the deceased indicated that they were not inflicted by the same weapon or by only one person, contradicting the claim of self-defense. The Court further established that treachery was present, as the attack was sudden, unexpected, and executed under the cover of darkness, with the appellants waylaying the victims and using deadly weapons to ensure the commission of the crime without risk to themselves. The Court also found that conspiracy was established by the series of acts done by each of the accused in pursuance of their common unlawful purpose, as they acted in concert in attacking the deceased and his companions. On the defenses of self-defense and alibi: The Court rejected the defense of self-defense, finding it highly unnatural and improbable for Artemio Pat, a newly-wed, to engage in a homicidal flight and bring his wife and mother with him. The bolo allegedly used by Artemio was never presented in court nor recovered. The Court also found the defense of alibi unmeritorious, as it was contradicted by the positive testimonies of prosecution witnesses who clearly identified the appellants at the scene of the crime. The Court reiterated that for alibi to prosper, it must not only be shown that the accused was at another place but that it was physically impossible for them to be at the scene of the crime. The testimonies of the appellants regarding their whereabouts were found to be negative in character and could not overcome the positive testimonies of the witnesses who saw them commit the crime. On treachery: The Court found treachery to be clearly established by the evidence. The attack on Artemio's group was sudden and unexpected, occurring under the cover of darkness. The appellants waylaid and ambushed the victims, attacking them with deadly weapons. The method of assault and the weapons used were deliberately chosen to ensure the commission of the crime without risk to the aggressors and without any defense from the deceased. The Court noted that six able-bodied men armed with deadly weapons overwhelmed the deceased, who was engaged in a futile fight for his life. On conspiracy: The Court held that conspiracy need not be proved by direct evidence but may be inferred from a series of acts done by each of the accused in pursuance of a common unlawful purpose. In this case, all the appellants acted in concert in attacking the deceased and his companions, encircling Artemio Pat and inflicting multiple stab wounds upon him with their weapons. The Court also noted that all the appellants belonged to the same family and lived close to each other, making it easy for them to band together and present a united front against the victims. On the penalty and application of the Indeterminate Sentence Law: The Court affirmed the trial court's finding of guilt but modified the penalty imposed on Fructuoso Mancao in Criminal Case No. 3787. While the trial court correctly appreciated the mitigating circumstance of voluntary surrender, it incorrectly applied the Indeterminate Sentence Law. The Court clarified that when a mitigating circumstance is appreciated, the penalty should be one degree lower. For Fructuoso Mancao, this meant the penalty should be reclusion temporal. Applying the Indeterminate Sentence Law, the minimum penalty should be within the maximum period of prision mayor, and the maximum penalty should be within the maximum period of reclusion temporal. The Court also increased the indemnity to the heirs of the deceased to P50,000.00.
Main Doctrine
The Court affirmed the conviction for Murder and Frustrated Murder, holding that the evidence presented by the prosecution was more convincing than the defenses of alibi and self-defense. The Court also clarified the application of the Indeterminate Sentence Law in cases with mitigating circumstances.