People v. Medted
REITERATIONFacts
The Antecedents: On September 25, 1937, at approximately 7 o'clock in the evening, Moro Manankian was fatally wounded by a spear thrust to his breast while he was cooking coconut oil in his house in Makamalig, barrio of Marang, Province of Cotabato. The crime was attributed to Datu Galantu Medted, Kanakan Medted, Mauti Dumaurong, and Makagaan. Procedural History: A complaint was filed in the justice of the peace court, followed by an information in the Court of First Instance of Cotabato. Makagaan was released upon motion of the fiscal due to lack of evidence. The remaining three appellants were convicted of murder and sentenced to reclusion perpetua, with indemnity and costs. The Petition: The appellants argued that the court erred in not sustaining their defense of double jeopardy and in finding them guilty despite insufficient evidence.
Issue(s)
Whether the defense of double jeopardy is tenable. Whether the guilt of the appellants for murder was established beyond reasonable doubt.
Ruling
The appealed judgment is affirmed in toto, with costs to the appellants. The appellants are to be credited with one-half of the preventive imprisonment they have undergone.
Ratio Decidendi
On the issue of double jeopardy: The defense of double jeopardy is unfounded. The preliminary investigation conducted in the justice of the peace court, which was dismissed upon motion of the fiscal for lack of evidence, does not constitute a trial or any part thereof. The purpose of a preliminary investigation is solely to determine if there are reasonable grounds to proceed against the accused. For double jeopardy to lie, there must be a former judgment of acquittal or conviction rendered by a competent court. The dismissal of a complaint during a preliminary investigation does not meet this requirement. On the issue of guilt: The guilt of the appellants for murder was established beyond reasonable doubt. The widow of the deceased, Sumeriñgan, positively identified the appellants as the perpetrators of the aggression. Although she initially stated to others that she could not recognize the assailants, her explanation for this silence was deemed satisfactory and convincing. She feared for her safety as she was a stranger in the area and had no relatives to protect her, and the relatives of the appellants were present during the initial investigation. She later revealed the identities of the perpetrators to Lieutenant Cabrera in confidence and subsequently at his headquarters after her husband's burial. Her testimony was corroborated by witness Mama, who saw the appellants fleeing the scene, each carrying spears and creeses. The motive for the crime was established as grave resentment stemming from a previous case where the deceased had accused the father and grandfather of the appellants of stealing carabaos, and the subsequent death of the grandfather after invoking divine retribution upon himself if he was lying. The lower court correctly found the qualifying circumstance of treachery, as the aggression was sudden and without warning, exposing the deceased to no risk. The aggravating circumstances of nighttime and dwelling were considered, but nighttime was absorbed by treachery. The mitigating circumstance of lack of instruction was given weight by the lower court.
Main Doctrine
A preliminary investigation, being a mere determination of probable cause and not a trial, cannot give rise to the defense of double jeopardy. The defense of double jeopardy requires a prior judgment of acquittal or conviction by a competent court.