People v. Matondo
REITERATIONFacts
The Antecedents: Gavina Gelsano, mother of appellant Elena Matondo, was assaulted in her home and died seven weeks later from complications. Elena Matondo was displeased with her mother's second marriage and the enjoyment of conjugal property by her stepfather. Elena allegedly procured fan-knives and instructed her chauffeur, Tomas Baring, to deliver one to Rufino Pelen, an ex-convict. Elena invited her mother to stay at Elena's house during a fiesta. Elena instructed her servant, Apolinaria Incierto, not to sleep in the same room as Gavina, but Apolinaria did not comply. Elena attended a dance and instructed Asuncion Ajero to accompany Tomas Baring to take two men, Rufino Pelen and Adriano Elicito, to Gavina's house. Baring drove Pelen and Elicito to a location near Elena's house, where they alighted, removed outer clothing, and proceeded to the house to kill Gavina Gelsano, with Elicito tasked to handle the dog. Pelen and Elicito entered the room and assaulted Gavina with a knife, inflicting multiple wounds. Gavina was unable to call for help immediately. Apolinaria Incierto saw Pelen and Elicito fleeing the room. Neighbors were alerted, and Elena was summoned. Procedural History: Elena Matondo allegedly confessed to Tomas Baring that she had her mother killed to prevent her stepfather from enjoying her mother's property and promised to reward Pelen and Elicito from insurance money. Baring drove Asuncion Ajero back to Matalom. Elena met Baring and made the alleged confession. Initially, charges of frustrated parricide and murder were filed. After Gavina's death, charges of parricide and murder were filed. Tomas Baring was later utilized as a witness after dismissal of charges against him. The Court of First Instance of Leyte found Elena Matondo guilty of parricide and Rufino Pelen and Adriano Elicito guilty of murder, sentencing them to life imprisonment and indemnification. The Petition: The defendants-appellants brought this appeal to reverse the judgment of the Court of First Instance.
Issue(s)
Whether the evidence presented sufficiently proves the guilt of Elena Matondo for parricide. Whether the evidence presented sufficiently proves the guilt of Rufino Pelen and Adriano Elicito for murder. Whether the testimonies of Tomas Baring and Asuncion Ajero are credible and admissible. Whether the circumstances enumerated by the trial court are sufficient to establish guilt beyond reasonable doubt.
Ruling
The judgment of the Court of First Instance of Leyte is affirmed in all respects. Elena Matondo is found guilty of parricide, and Rufino Pelen and Adriano Elicito are found guilty of murder. They are sentenced to life imprisonment and jointly and severally to indemnify the heirs of Gavina Gelsano in the amount of P1,000, plus costs.
Ratio Decidendi
On the guilt of Elena Matondo for parricide: The Court found sufficient evidence to establish Elena Matondo's guilt. This was based on numerous circumstances, including her direction to Tomas Baring to take Pelen and Elicito to the scene, her delivery of a knife to Pelen, her admission to Baring of having orchestrated the killing to prevent her stepfather from enjoying her mother's property, her attempts to mislead Asuncion Ajero, her use of flattery and menaces to secure silence, her efforts to have Ajero sent away, her instructions to Apolinaria Incierto regarding sleeping arrangements, her promises to Incierto, her attempts to influence the chief of police regarding Baring's innocence, her procurement of declarations emphasizing the unknown identity of the offenders, her lack of interest in her mother's condition, and her overall conduct indicating a desire for her mother's death. The Court considered her admission to Baring as a strong piece of evidence, coupled with the other circumstances, making out a convincing case. On the guilt of Rufino Pelen and Adriano Elicito for murder: The guilt of Rufino Pelen was established by his own affidavit, wherein he admitted being hired to kill Gavina Gelsano and entering the house with another person for that purpose. While he claimed Tomas Baring was his companion and the actual killer, this was contradicted by other evidence. For Adriano Elicito, the testimony of Tomas Baring and Asuncion Ajero placed him at the scene with Pelen. Furthermore, Apolinaria Incierto testified that Elicito was one of the two individuals she saw fleeing the room after the assault. The Court found this evidence sufficient to convict them of murder. On the credibility of Tomas Baring and Asuncion Ajero: The Court acknowledged the potential issues with the testimonies of Tomas Baring and Asuncion Ajero, particularly given Baring's initial involvement and Ajero's subsequent recantation. However, the Court gave weight to Baring's testimony regarding Elena's confession, finding it consistent with other evidence. The Court also noted that Ajero's later statements, which recanted her trial testimony, were not convincing and appeared to be post-trial efforts to divert the court. The trial judge, who had the advantage of observing the witnesses directly, found their testimonies credible enough to form the basis of his conclusions. On the sufficiency of the enumerated circumstances: The Court found that the twelve circumstances enumerated by the trial court, when considered in conjunction with the direct admission made by Elena Matondo to Tomas Baring, constituted a strong array of evidence pointing to her guilt. The Court reasoned that the motive was clear (preventing the stepfather from enjoying the property), and the victim had no known enemies who would commit the crime out of mere malice. The Court concluded that these circumstances, when given their true weight, were convincing and sufficient to establish guilt beyond reasonable doubt, despite the defense's attempts to discredit key witnesses and introduce new affidavits.
Main Doctrine
The Court affirmed the conviction of Elena Matondo for parricide and her co-accused for murder, finding sufficient evidence of conspiracy and inducement, despite attempts to cover up the crime and conflicting testimonies.