People v. Entrialgo
REITERATIONFacts
The Antecedents: Appellant Pancho Entrialgo was charged with two counts of murder for the deaths of Benjamin and Avelina Tabang. The prosecution alleged that on July 30, 2000, the appellant, armed with a bolo and motivated by ill-feelings towards Benjamin Tabang (who had dismissed him from his barangay tanod position), intentionally killed both victims. The victims sustained multiple hacking wounds, with Benjamin suffering four and Avelina three hacking wounds and two lacerated wounds, both succumbing to their injuries. Procedural History: The case was initially tried before the Regional Trial Court (RTC) of Puerto Princesa City, Branch 49. Despite the absence of eyewitnesses, the RTC found the appellant guilty of murder in the killing of Benjamin Tabang and homicide in the killing of Avelina Tabang, considering evident premeditation as a qualifying circumstance for Benjamin's death and nighttime as an aggravating circumstance for both. The RTC sentenced the appellant to death for murder and to seventeen years, four months, and one day to twenty years imprisonment for homicide. The Court of Appeals affirmed the RTC's decision in its entirety. The Petition: This case reached the Supreme Court on appeal. The appellant contested the findings of guilt and the penalties imposed by the lower courts. The Supreme Court, in its decision, affirmed the appellant's guilt for murder and homicide. In light of Republic Act No. 9346, the death penalty for murder was commuted to reclusion perpetua without eligibility for parole. The sentence for homicide was modified to an indeterminate imprisonment from a minimum of 12 years of prision mayor in its maximum period to a maximum of 20 years of reclusion temporal in its maximum period. The Court also affirmed the civil indemnities and awarded moral damages to the heirs of both victims.
Issue(s)
Whether appellant Pancho Entrialgo is guilty beyond reasonable doubt of murder for the death of Benjamin Tabang. Whether appellant Pancho Entrialgo is guilty beyond reasonable doubt of homicide for the death of Avelina M. Tabang. Whether treachery and evident premeditation were present in the killing of Benjamin Tabang and Avelina M. Tabang. Whether nighttime was a qualifying or aggravating circumstance in the killings; and the weight of evidence and the penalties and damages to be awarded.
Ruling
The Supreme Court affirmed the guilt of appellant Pancho Entrialgo for murder in Criminal Case No. 16095 and homicide in Criminal Case No. 16096. The Court sentenced him to reclusion perpetua without eligibility for parole for murder, and to an indeterminate imprisonment from 12 years of prision mayor in its maximum period to 20 years of reclusion temporal in its maximum period for homicide. Appellant was also ordered to pay civil indemnity and moral damages to the heirs of both victims.
Ratio Decidendi
On the guilt for murder (Criminal Case No. 16095): The Court found appellant guilty of murder for the death of Benjamin Tabang. The prosecution's evidence established appellant's motive and his confession. Denials cannot prevail over positive declarations of prosecution witnesses. The presence of treachery was established as the attack was sudden and unexpected, giving Benjamin no opportunity to defend himself. The Court also found evident premeditation present. The aggravating circumstance of nighttime was also considered as it facilitated the commission of the offense. On the guilt for homicide (Criminal Case No. 16096): The Court affirmed the conviction for homicide for the death of Avelina M. Tabang. While evident premeditation was not found to be present with respect to Avelina, the killing was still qualified by treachery. The attack on Benjamin also encompassed Avelina, who was present at the time, and she was likewise deprived of any opportunity to defend herself. The Supreme Court maintained the conviction for homicide, applying the indeterminate sentence. On the qualifying and aggravating circumstances: The Court found treachery to be present in both killings, as the victims were attacked without any possibility of defense. Evident premeditation was found to be present only with respect to Benjamin Tabang, as there was a clear showing of planning and deliberation. The aggravating circumstance of nighttime was considered in both cases, as it was deliberately sought by the appellant to facilitate the commission of the crime and ensure impunity. On the weight of evidence and the penalties and damages: The Court gave more weight to the positive testimonies of the prosecution witnesses over the uncorroborated denial of the appellant. The Court also considered the motive established by the prosecution. The Court imposed the penalty of reclusion perpetua without eligibility for parole for the murder of Benjamin Tabang. For the homicide of Avelina M. Tabang, the Court imposed an indeterminate sentence. The Court also ordered the payment of civil indemnity and moral damages to the heirs of both victims.
Main Doctrine
Denials, being inherently weak, cannot prevail over the positive declarations of prosecution witnesses, especially when the denial is uncorroborated. The presence of treachery and evident premeditation can qualify the crime to murder, and the aggravating circumstance of nighttime can be considered when it facilitates the commission of the crime.