People v. Amazan
REITERATIONFacts
The Antecedents: On April 27, 1997, in Barangay San Vicente, Dimasalang, Masbate, Artemio Arma was hacked on the head and killed. His wife, Amparo Arma, was hacked on the face by Jaime Amazan, and his son, Antonio Arma, was hacked on the face and hand by Danilo Villegas. The prosecution alleged that Jerito Amazan, Jaime Amazan, and Danilo Villegas conspired to commit murder and attempted murder. The defense claimed self-defense and defense of a relative, alleging that the Armas initiated the aggression. Procedural History: The Regional Trial Court (RTC), Branch 44, Masbate, found Jerito Amazan, Jaime Amazan, and Danilo Villegas guilty of murder for the death of Artemio Arma, and guilty of attempted homicide for the wounding of Amparo Arma and Antonio Arma, respectively. The RTC sentenced them accordingly. The Petition: The accused-appellants appealed the decision of the RTC, raising several assignments of error concerning the credibility of witnesses, the presence of treachery and conspiracy, the rejection of their defense, and the appreciation of aggravating and mitigating circumstances.
Issue(s)
Whether the trial court erred in giving weight and credence to the testimonies of the prosecution witnesses. Whether the qualifying circumstance of treachery was attendant in the commission of the crime. Whether conspiracy existed among the accused-appellants. Whether the defense of relative interposed by the accused-appellants should have been considered. Whether Jaime Amazan was guilty of attempted homicide, which should be modified to attempted murder, in wounding Amparo Arma. Whether Danilo Villegas was guilty of attempted homicide for wounding Antonio Arma. Whether the aggravating circumstances of evident premeditation, abuse of superior strength, and nighttime were present, and whether the mitigating circumstance of voluntary surrender should be credited. Whether the award of damages was proper.
Ruling
The Supreme Court modified the decision of the Regional Trial Court. It affirmed the conviction for murder in Criminal Case No. 8494, sentencing Jerito Amazan, Jaime Amazan, and Danilo Villegas to reclusion perpetua. In Criminal Case No. 8496, Jaime Amazan was found guilty of attempted murder, not attempted homicide, and sentenced to an indeterminate penalty. In Criminal Case No. 8497, Danilo Villegas was found guilty of attempted homicide and sentenced to an indeterminate penalty. The Court also awarded additional moral damages to the heirs of Artemio Arma.
Ratio Decidendi
On the credibility of prosecution witnesses: The Court held that inconsistencies in minor details do not affect the credibility of witnesses, especially considering the age and inexperience of a young witness like Alberto Arma. The Court noted that Alberto's confusion was attributable to his age, nervousness, and the poor lighting conditions during the incident. The Court also found that alleged contradictions between sworn statements and testimonies in court were either explainable or were not properly raised during the trial for the witnesses to explain. On the presence of treachery: The Court found that treachery was present in the killing of Artemio Arma. The victim sustained two head wounds at the parieto-occipital area, indicating that the attack was made from behind and that the victim had no opportunity to defend himself. The first fatal wound rendered the victim helpless against subsequent attacks, fulfilling the elements of treachery. On the existence of conspiracy: The Court found that conspiracy was established by the concerted actions of the accused-appellants. They came together at the scene, were all armed, participated in the attack, made no effort to stop the assault, and fled together. The Court noted that Danilo Villegas' participation was evident when he checked on the fallen victim and then turned to attack Antonio Arma, demonstrating a common criminal purpose. On the defense of relative: The Court rejected the defense of relative. The accused-appellants failed to prove the requisites of unlawful aggression, reasonable necessity of the means employed, and lack of participation in provocation. Jerito's claim of self-defense was contradicted by the location of Artemio's wounds, indicating an attack from behind. The Court also found it improbable that the Armas, who were neighbors and relatives, would initiate an attack. On the conviction for wounding Amparo Arma (Crim. Case No. 8496): The Court modified the conviction from attempted homicide to attempted murder. While the wounds were not fatal, the act of hacking Amparo on the face with a bolo demonstrated an intent to kill. The Court also appreciated the aggravating circumstance of abuse of superior strength, as Amparo was unarmed and attacked without warning. The penalty was adjusted accordingly. On the conviction for wounding Antonio Arma (Crim. Case No. 8497): The Court affirmed the conviction for attempted homicide. Antonio's wounds were not fatal, but the hacking on the face indicated an intent to kill. The Court adjusted the penalty to an indeterminate sentence, considering the absence of aggravating and mitigating circumstances. On aggravating and mitigating circumstances: The Court found no evident premeditation or nighttime as aggravating circumstances. Abuse of superior strength was deemed absorbed in treachery for the murder charge but was appreciated for the attempted murder of Amparo. The Court credited the mitigating circumstance of voluntary surrender to Jerito and Jaime Amazan. The penalty for murder was reclusion perpetua, considering the mitigating circumstance. The penalties for attempted murder and attempted homicide were adjusted to indeterminate sentences. On damages: The Court affirmed the indemnity for death and awarded an additional P50,000.00 as moral damages to the heirs of Artemio Arma.
Main Doctrine
The Supreme Court affirmed the conviction of Jerito Amazan, Jaime Amazan, and Danilo Villegas for murder in the killing of Artemio Arma, modified the conviction of Jaime Amazan for the wounding of Amparo Arma from attempted homicide to attempted murder, and affirmed the conviction of Danilo Villegas for attempted homicide in the wounding of Antonio Arma. The Court also clarified the application of aggravating and mitigating circumstances and awarded moral damages.