People v. Bandojo
REITERATIONFacts
The Antecedents: The underlying dispute concerns the fatal stabbing of Isidro Tanes. While Tanes was drinking water at his home on the evening of June 7, 1939, he was wounded in the abdomen with a bolo. He died from this wound the following day. The assailant was identified by Tanes' wife as the appellant, Jose Bandojo, who was seen fleeing the scene immediately after the attack. Procedural History: The appellant was convicted of murder by the Court of First Instance of Iloilo and sentenced to reclusion perpetua and to pay an indemnity to the heirs of the deceased. The appellant appealed this conviction. The appellate court, after reviewing the evidence and the defense presented, found the conviction to be in accordance with the law. The Petition: The appellant's appeal is based on a defense of alibi, asserting he was not present at the scene of the crime. However, the appellate court found this alibi to be without merit due to the proximity of the locations and the testimonies of witnesses who placed the appellant fleeing the scene. The court also considered the aggravating circumstances of treachery and dwelling. Despite the presence of these circumstances, the court affirmed the sentence of reclusion perpetua, noting that the penalty of death was not unanimously imposed.
Issue(s)
Whether the guilt of the accused-appellant for the crime of murder was proven beyond reasonable doubt. Whether the circumstances of treachery and dwelling were properly appreciated as qualifying and aggravating circumstances, respectively.
Ruling
The Supreme Court affirmed the decision of the lower court, sentencing the appellant to reclusion perpetua and ordering him to pay P2,000 to the heirs of Isidro Tanes, plus costs. The Court found the evidence sufficient to establish the guilt of the accused beyond reasonable doubt.
Ratio Decidendi
On Issue 1: The guilt of the accused-appellant was proven beyond reasonable doubt. The testimony of the victim's wife, Esperanza Betita, established that she saw the appellant sheathing his bolo and fleeing immediately after her husband was wounded. This was corroborated by Julian Betita, a neighbor, who encountered the appellant running away from the scene. Furthermore, Diosdado Benzurto, a relative of the appellant, testified that the appellant admitted to stabbing Isidro Tanes because Tanes refused to relinquish his work as a road overseer. The appellant's claim of an alibi was found to be weak and unconvincing, given the short distances between his alleged location and the crime scene, which could easily be traversed on foot. The presence of scratches and wounds on the appellant's body, consistent with having passed through a barbed-wire fence, further supported his presence at the crime scene, as the victim's property was fenced with barbed wire. These pieces of circumstantial evidence, taken together, conclusively pointed to the appellant as the perpetrator. On Issue 2: The qualifying circumstance of treachery (alevosia) was properly appreciated. The victim was attacked while drinking water, without any opportunity to defend himself, and the attack was sudden and unexpected, directly insuring the execution of the crime without risk to the offender. The aggravating circumstance of dwelling (morada) was also correctly considered, as the crime was committed in the victim's house. The Court noted that the penalty for murder, which is death, could not be imposed due to the lack of unanimity among the Justices. Therefore, the penalty immediately lower in degree, reclusion perpetua, was imposed, in accordance with Article 133 of the Revised Administrative Code, as amended by Commonwealth Act No. 3.
Main Doctrine
The Supreme Court affirmed the conviction for murder, holding that the qualifying circumstance of treachery was sufficiently established by evidence showing the victim was attacked without warning while in the act of drinking water, thus preventing any defense. The Court also considered the aggravating circumstance of dwelling. Despite the death penalty being imposable, it was not unanimously imposed, leading to the imposition of reclusion perpetua as the immediately lower penalty.