People v. Chan Lin Wat
REITERATIONFacts
The Antecedents: Manuel Escarella was investigating a warehouse fire and its insurance claim, which apparently involved one Tan Yong. On a night in September 1925, several Chinese men, including Tan Yong and appellant Chan Lin Wat, gathered at Tan Yong's residence. Tan Yong asked who was brave enough to kill someone, and Chan Lin Tam volunteered. Tan Yong offered a reward of P500 to those who would help, with the victim being Manuel Escarella, due to his investigation. Tan Yong planned another dinner, inviting Escarella, and tasked Chan Lin Wat, who was intimate with Escarella, to extend the invitation and provided P5 for expenses. Chan Lin Wat met Escarella and they, along with Chan Lin Tam, were picked up by Lim Sio Chong in an automobile. They had dinner with Tan Yong at a panciteria. The automobile used was registered in Lim Sio Chong's name but recently purchased by Tan Yong; Chan Lin Wat had arranged its use with Lim Sio Chong the previous day. After dinner, they went to the Luneta, then a house of ill-fame in Pasay, and finally decided to drive to Pasig. Near Fort McKinley, the car was stopped. Lim Sio Chong claimed he did not stop the car and found the electrical switch turned off, suspecting Chan Lin Tam. Tan Yong instructed Lim Sio Chong not to use the starter due to a weak battery and to crank the car. Tan Yong ordered Chan Lin Wat to crank the car and asked Escarella to get out so Chan Lin Wat could access the tool. Escarella exited the car and was struck in the back of the head with the cranking tool by Chan Lin Wat. Escarella asked why he was struck, received a kick from Chan Lin Wat, and fell. Chan Lin Wat, Tan Yong, and Chan Lin Tam surrounded Escarella and inflicted further injuries. Lim Sio Chong claimed he started the car to flee but was threatened by Chan Lin Wat to wait. The assailants re-entered the car, leaving Escarella on the roadside. Procedural History: The Court of First Instance of Rizal found appellant Chan Lin Wat guilty of murder, sentencing him to death, to indemnify the heirs of Manuel Escarella in the amount of P1,000, and to pay the costs. This appeal seeks to reverse that judgment. The Petition: The appellant seeks to reverse the judgment of the Court of First Instance of Rizal finding him guilty of murder and imposing the death penalty.
Issue(s)
Whether the appellant is guilty of murder. Whether the dying declarations of the victim were admissible. Whether the court had jurisdiction to allow the discharge of Lim Sio Chong as a witness for the prosecution. Whether the conspiracy established the guilt of the appellant for the acts of his co-conspirators.
Ruling
The Supreme Court affirmed the judgment of the Court of First Instance of Rizal, finding the appellant guilty of murder and upholding the sentence of death. The Court held that the crime was deliberately planned and that all four persons concerned were principals, either by direct participation or by aiding the actual slayer. The Court also affirmed the admissibility of the dying declarations and the court's jurisdiction to discharge Lim Sio Chong as a witness. The sentence of death was ordered to be carried into effect.
Ratio Decidendi
On the guilt of the appellant and conspiracy: The Court found that the crime was deliberately planned and that the appellant was a principal by conspiracy. The testimony of Lim Sio Chong, though an accomplice, was corroborated by the appellant's written confession and the dying declarations of the victim. The Court emphasized the well-settled proposition that in carrying a conspiracy into effect, every act of one of the conspirators in furtherance of the common purpose is, in contemplation of law, the act of all. Therefore, regardless of who struck the fatal blow, the appellant was guilty of murder as a member of the conspiracy. The Court noted the scheme to make it appear that the victim was killed by an automobile, which was frustrated by the victim's survival to identify his assailants. On the admissibility of dying declarations: The Court held that the dying declaration made by Escarella to his wife might be questionable, but the subsequent declaration made to secret service agents shortly before his death was admissible. The victim's extreme weakness at the time of this declaration, coupled with his death shortly thereafter, allowed for the inference that he knew death was impending and had given up hope of survival. The Court clarified that it is not necessary for the declarant to explicitly state that he has given up hope of life; it is sufficient if such a state of mind can be inferred from the circumstances. On the jurisdiction to discharge Lim Sio Chong: The Court found the contention that the court was without jurisdiction to allow Lim Sio Chong to be discharged as a witness to be untenable. Although a separate trial had been ordered for the accused, they were prosecuted under a joint information. The Court held that the right of the court to order the discharge of one accused to be admitted as a witness for the prosecution is not negated by an order of severance. On the qualifying and aggravating circumstances: The Court found the qualifying circumstance of evident premeditation and the aggravating circumstance of treachery (alevosia) to be present. Nocturnity was considered absorbed in alevosia. The Court concluded that the presence of evident premeditation and treachery justified the imposition of the penalty appropriate to murder in its maximum degree, which was death.
Main Doctrine
In a conspiracy, every act of one conspirator in furtherance of the common purpose is, in contemplation of law, the act of all. The penalty for murder, with the qualifying circumstance of evident premeditation and the aggravating circumstance of treachery, is the maximum degree.