People v. Tañedo
REITERATIONFacts
The Antecedents: On April 25, 1982, at around 6:00 PM, Domingo and Dominador Nepal passed by the store of Merly Pelago. A drinking spree was ongoing involving several individuals. An altercation occurred between Ruben Agoncillo and Danilo Mercadal, with Jesus Lachica intervening. Later, at around 7:00 PM, as Domingo and Dominador were leaving, they were asked by a drunk Ruben Agoncillo to accompany him to the Barangay Captain. As Domingo and Dominador were proceeding home, with Domingo ahead, they were ambushed by Virgilio Tañedo, Berlito Lachica, Jesus Lachica, Enrico Gepaya, and Mercurio Lemina, all armed with bladed weapons. They emerged from a banana grove and a nearby house. Danilo Mercadal initially hacked Domingo on the head. Virgilio Tañedo then delivered a final thrust with his balisong. The other assailants surrounded Domingo, and he was killed. Maxima Remuyan, mother of the victim, witnessed the assault. Procedural History: Virgilio Tañedo, Berlito Lachica, Danilo Mercadal, Mercurio Lemina, Jesus Lachica, and Enrico Gepaya were charged with murder. The trial court convicted all accused of murder and sentenced them to twelve (12) years of prision mayor to twenty (20) years of reclusion temporal, and to indemnify the heirs of Domingo Nepal. Accused Jesus Lachica died pending appeal, and his case was terminated. Virgilio Tañedo, Berlito Lachica, and Danilo Mercadal appealed to the Court of Appeals. The Court of Appeals affirmed the conviction but modified the sentence to reclusion perpetua and increased the indemnity to P50,000.00. The case was certified to the Supreme Court for review. The Petition: The accused-appellants argued that their conviction was based on misappreciated testimonies of prosecution witnesses, that the crime committed was homicide and not murder, and that treachery could not be appreciated due to a casual encounter.
Issue(s)
Whether the testimonies of the prosecution witnesses were properly appreciated by the lower courts. Whether the crime committed was homicide or murder. Whether treachery qualified the killing to murder.
Ruling
The Supreme Court affirmed the conviction of Virgilio Tañedo, Berlito Lachica, and Danilo Mercadal for murder qualified by treachery. The sentence of reclusion perpetua and the indemnity of P50,000.00 were upheld.
Ratio Decidendi
On the appreciation of testimonies and credibility of witnesses: The Court reiterated the rule that findings of fact of the trial court regarding the credibility of witnesses are given great weight and respect, as the trial court had the opportunity to observe their demeanor. The Court found no reason to depart from this rule. The lower court did not disregard defense witnesses' testimonies but found them unbelievable compared to the credible testimonies of prosecution witnesses. The Court also noted that alibi is the weakest of all defenses and requires proof of physical impossibility to be at the scene of the crime, which the defense failed to establish. The Court found the prosecution witness Maxima Remuyan's testimony credible, stating that her hearing her son call out names did not preclude the participation of others, as she categorically identified all the assailants. On whether the crime committed was homicide or murder: The Court held that the killing was qualified to murder by treachery. The records showed that the assailants hid behind a banana grove and a house, waiting for the victim. They emerged simultaneously and assaulted Domingo with bladed weapons, ensuring the killing without risk to themselves and preventing any defense from the victim. This coordinated ambush could not be described as a casual encounter. The Court emphasized that treachery is present when the offender employs means, methods, or forms in the execution of the crime which tend directly and specially to insure its execution without risk to himself arising from any defense the offended party might make. The trial court correctly ruled that treachery qualified the killing to murder, absorbing other qualifying circumstances like abuse of superior strength and nighttime. On the appreciation of treachery: The Court found that treachery was present. The assailants lay in wait and emerged from hiding places to launch a surprise, coordinated attack with bladed weapons. This method of execution directly and specially insured the commission of the crime without risk to the offenders, as the victim was completely unable to defend himself. The Court cited its own jurisprudence, stating that treachery is present when the offender employs means, methods, or forms in the execution thereof which tend directly and specially to insure its execution, without risk to himself arising from any defense which the offended party might make. The trial court and the appellate court correctly ruled that treachery qualified the killing to murder.
Main Doctrine
The concerted action of armed assailants who lay in wait for an unsuspecting victim, employing means and methods to insure the killing without risk to themselves, constitutes treachery, qualifying the offense to murder. Alibi, being the weakest of defenses, requires proof of physical impossibility to be at the scene of the crime.