People v. Medice
REITERATIONFacts
The Antecedents: On May 18, 2001, appellant Nestor Medice and Eduardo Dollendo were accused of Murder. The information alleged that on February 13, 2001, at around 2:30 PM, in the house of Deolito Romines at Barangay West, San Jose, Northern Samar, Dollendo, with the alleged assistance of Medice, stabbed and killed the victim, Garry Ruiz. Eyewitnesses Deolito Romines and Joseph del Valle testified that Medice arrived first, left, and returned with Dollendo. Medice handed a bolo to Dollendo, saying, "Uh! [Y]ou take care of it," after which Dollendo stabbed Ruiz. Ruiz sustained four stab wounds, two of which caused his death. Dr. Norma E. Dato confirmed the cause of death as shock secondary to internal hemorrhage caused by stab wounds. Medice denied the charge, claiming he was elsewhere and did not see Dollendo on the day of the incident. He learned of Ruiz's death only upon his apprehension on March 2, 2001. The defense presented an alibi that Medice was at the house of Dafia Pusio and Dondon Morino, which was only forty meters away from the crime scene. Procedural History: The Regional Trial Court (RTC), Branch 19, Catarman, Northern Samar, convicted Nestor Medice of Murder on April 30, 2003, sentencing him to reclusion perpetua and ordering him to pay civil indemnity and moral damages. The Court of Appeals (CA) affirmed the RTC decision on November 28, 2006, with a modification to include exemplary damages. Medice appealed to the Supreme Court. The Petition: The appellant sought to overturn his conviction for murder.
Issue(s)
Whether appellant Nestor Medice is guilty beyond reasonable doubt of the crime of Murder. Whether treachery attended the killing of Garry Ruiz. Whether evident premeditation was established as an aggravating circumstance. Whether conspiracy to commit murder was sufficiently proven. Whether the defense of alibi is tenable.
Ruling
The Supreme Court affirmed the conviction of Nestor Medice for Murder, sentencing him to suffer the penalty of reclusion perpetua. He was ordered to pay the heirs of Garry Ruiz P50,000.00 as civil indemnity, P50,000.00 as moral damages, P25,000.00 as temperate damages, and P30,000.00 as exemplary damages, with interest at six percent (6%) per annum from the finality of judgment until fully paid.
Ratio Decidendi
On the guilt of Nestor Medice for Murder: The Court affirmed Medice's conviction, holding that the elements of murder were present: a person was killed, the accused killed him (through conspiracy), the killing was qualified by treachery, and it did not constitute parricide or infanticide. The Court found that the prosecution established Medice's guilt beyond reasonable doubt through the testimonies of eyewitnesses and the established conspiracy. The Court reiterated that to be convicted of murder, the killing must be attended by qualifying circumstances enumerated in Article 248 of the Revised Penal Code. The Court found that treachery was present, qualifying the killing to murder, and that conspiracy was sufficiently proven by a chain of circumstances, making Medice liable as a principal by induction. On Treachery qualifying the killing to murder: The Court held that treachery qualified the killing to murder. Treachery is present when the offender employs means, methods, or forms of execution that tend directly and specially to insure the commission of the crime without risk to himself arising from the defense the victim might make. The eyewitness accounts clearly showed that the attack was sudden and unexpected, with the victim unaware of the impending assault. Medice's actions, including handing the bolo to Dollendo and stepping back, ensured that Ruiz had no opportunity to resist or defend himself. The Court clarified that qualifying circumstances need not be expressly stated as such in the information to be properly considered. On Evident Premeditation: The Court ruled that evident premeditation was not established as an aggravating circumstance. For evident premeditation to be considered, there must be proof of the time the offender determined to commit the crime, an act indicating adherence to that determination, and a sufficient lapse of time between the determination and execution for reflection. In this case, the testimony that Medice and Dollendo looked for Ruiz and mentioned a problem was insufficient to prove a prior decision to kill. Furthermore, the two-minute interval between Medice checking on Ruiz and the attack was not enough time for cool thought and reflection, which is the essence of premeditation. On Conspiracy to commit murder: The Court found that conspiracy to commit murder was clearly established. The evidence showed that Medice ascertained Ruiz's presence, fetched Dollendo, provided the weapon, and fled with Dollendo after the stabbing. These actions, taken collectively, demonstrated a community of criminal design to kill the victim. The Court emphasized that a conspirator need not participate in every detail of the execution; the act of one conspirator is the act of all once conspiracy is shown, making all conspirators principals. On the Defense of Alibi: The Court rejected Medice's defense of alibi. The Court reiterated that alibi can only prosper if the accused proves not only that he was elsewhere but also that it was physically impossible for him to have been at the locus criminis. Medice admitted that the house where he claimed to be was only forty meters away from the crime scene, making it physically possible for him to have been present. Moreover, the positive identification by credible eyewitnesses destroyed the defense of alibi and denial.
Main Doctrine
Conspiracy to commit murder is established by a chain of circumstances showing a community of criminal design, making each conspirator liable for the acts of the others, even if only one physically committed the stabbing. Treachery qualifies the killing to murder when the attack is sudden and unexpected, affording the victim no opportunity to defend himself. Alibi fails if it is not physically impossible for the accused to be at the locus criminis.