People v. Go-od
REITERATIONFacts
The Antecedents: On May 8, 1991, at around 5:30 PM, in Cataingan, Masbate, Aladino Ygot was attacked by Alejandro Go-od, Nestor Go-od, Sancho Go-od, Rufo Go-od, and Empe Go-od. The victim was looking for his goat and suspected the accused of stealing it. The accused, emerging from banana plants, simultaneously hacked and stabbed the victim with bolos and a spear until he fell to the ground. The victim sustained multiple hack and stab wounds, causing his instantaneous death. During the assault, the victim managed to grab a bolo and wounded Nestor Go-od, who was then hospitalized for two weeks. Procedural History: Accused-appellant Nestor Go-od, along with his father Alejandro Go-od, were charged with murder. Alejandro died during detention. Only Nestor's case proceeded to trial. The Regional Trial Court of Cataingan, Masbate, found Nestor Go-od guilty of murder and sentenced him to reclusion perpetua, ordering him to indemnify the heirs of the victim. The Petition: Accused-appellant Nestor Go-od appealed the RTC decision, contending that the lower court erred in not considering that he was fatally wounded by the victim, thus rendering him incapable of inflicting any injury that led to the victim's death.
Issue(s)
Whether the guilt of accused-appellant Nestor Go-od for murder has been established beyond reasonable doubt. Whether the qualifying circumstance of treachery was present. Whether abuse of superior strength can be appreciated as a separate aggravating circumstance alongside treachery. Whether the award for loss of earning capacity, civil indemnity, moral damages, and exemplary damages are proper.
Ruling
The Supreme Court affirmed the conviction of Nestor Go-od for murder, modifying the awarded damages. The penalty of reclusion perpetua was upheld. The award for exemplary damages was deleted, and the award for loss of earning capacity was modified.
Ratio Decidendi
On the guilt of accused-appellant Nestor Go-od for murder: The Court held that the guilt of accused-appellant Nestor Go-od has been established beyond reasonable doubt. This was based on the positive identification by prosecution witnesses Anecia Monsalud and Gaudioso Suson. The defense of denial and non-participation by the accused-appellant was deemed insufficient to overcome the strong positive identification. The Court emphasized that once conspiracy is established, the act of one conspirator is the act of all, making them equally liable as co-principals. The fact that the victim was able to wound Nestor Go-od did not exculpate him, as the death occurred after the concerted assault by all the accused. The Court reiterated that it is unnecessary to pinpoint who inflicted the fatal blow when conspiracy is proven. On the qualifying circumstance of treachery: The Court affirmed the trial court's finding of treachery. Treachery was present because the accused employed means and methods that tended directly and specially to insure the execution of the crime without risk to themselves. The five accused launched a sudden, deliberate, and unexpected attack on the unsuspecting and unarmed Aladino Ygot, who was given no opportunity to defend himself or repel the initial assault. They emerged from banana plants and attacked simultaneously with bolos and a spear. The fact that the victim managed to stab Nestor Go-od after being wounded does not negate treachery, as it must be present at the inception of the attack. On abuse of superior strength as a separate aggravating circumstance: The Court ruled that the trial court erred in appreciating abuse of superior strength in addition to treachery. It is well-settled that treachery, when qualifying the crime to murder, absorbs abuse of superior strength. The presence of five armed assailants against an unarmed victim, while indicative of superior strength, cannot be appreciated independently because it is considered absorbed in alevosia (treachery). On the award for damages: The Court upheld the P50,000.00 civil indemnity for death, as it conforms with prevailing jurisprudence. The P30,000.00 moral damages were also deemed reasonable for the pain suffered by the victim's widow. However, the award of exemplary damages was deleted because no aggravating circumstances were proven to justify it. The award for loss of earning capacity was modified. Using the formula provided, the Court computed the net earning capacity to be P792,000.00, based on the victim's age, monthly income, and life expectancy.
Main Doctrine
Once conspiracy is established, all conspirators are liable as co-principals regardless of the extent of their participation, as the act of one is the act of all. Treachery, when qualifying the crime to murder, absorbs abuse of superior strength.