People v. Gallego
REITERATIONFacts
The Antecedents: On April 24, 1947, Conrado Soriano and Romeo Lacson visited Esteban Uy's store, asking for money and rice, which Uy refused. Soriano warned Uy that they would not meet for three days. On April 27, 1947, Sixto Impe, an employee of Uy, met the four appellants (Delfin Gallego, Conrado Soriano, Romeo Lacson, and Dominador Vergara) who were drinking tuba. Soriano invited Impe to join them and later to follow them to Uy's house, warning Impe not to tell anyone or they would kill him. Upon arrival at Uy's house, Soriano and Gallego entered an alley. Gallego climbed on Soriano's shoulders to enter a window of Uy's house. Soriano gave Gallego a hand grenade, which Gallego threw into a room after jumping down. The hand grenade exploded, killing Esteban Uy. Tan Sin Tay, Uy's wife, heard the explosion upon returning to their room and found her husband dead. Procedural History: The trial court found the appellants guilty of murder and sentenced them to reclusion perpetua, to indemnify the heirs of Esteban Uy in the amount of P2,000, and to pay costs. The appellants appealed the decision. The Petition: The appellants set up alibi as their defense and claimed that the affidavits of Vergara and Lacson admitting participation were made under duress. They also insinuated that Impe was solely responsible for the crime.
Issue(s)
Whether the guilt of the appellants was proven beyond reasonable doubt. Whether the alibi presented by the appellants was sufficient to overcome the evidence of the prosecution. Whether the extrajudicial confessions of Vergara and Lacson were voluntary and admissible in evidence. Whether Sixto Impe was the sole perpetrator of the crime. Whether the penalty and indemnity imposed by the trial court were proper.
Ruling
The Supreme Court affirmed the decision of the trial court with modifications. The appellants were found guilty of murder, sentenced to reclusion perpetua, and the indemnity to the heirs of Esteban Uy was increased to P6,000. The Court found that the evidence presented sufficiently established the conspiracy and participation of all four appellants in the commission of the crime.
Ratio Decidendi
On the guilt of the appellants: The Court found that the testimonies of Sixto Impe and Luis Demalata positively identified the four appellants as being present at the scene of the crime before the explosion. The testimony of Impe, detailing the conspiracy and the actions of each appellant, was corroborated by Demalata's sighting of them in the vicinity. The Court gave credence to these testimonies, finding no motive for Impe or Demalata to falsely implicate the appellants. The Court also considered the extrajudicial confessions of Vergara and Lacson, despite their claims of duress, as further evidence of their participation. On the alibi: The Court rejected the alibi presented by the appellants, stating that it could not prevail over the positive testimonies of the prosecution witnesses who identified them at the scene of the crime. The Court emphasized that alibi is a weak defense, especially when not supported by credible and independent evidence, and that the prosecution witnesses had no apparent motive to fabricate their testimonies against the appellants. On the extrajudicial confessions: The Court found that the claims of duress regarding the extrajudicial confessions of Vergara and Lacson were not substantiated. The testimonies of Judge Amante, Assistant City Attorney Villarosa, and detectives Sumagaysay, Homogod, and Vasquez belied these claims. Furthermore, Lacson swore to his confession in the presence of his sister and brother-in-law, lending credibility to its voluntary execution. The Court also noted that Impe's alleged confession, Exhibit 3-Gallego, was found to be involuntary due to maltreatment, as testified by Impe himself and corroborated by other witnesses. On Sixto Impe's sole responsibility: The Court dismissed the insinuation that Impe was solely responsible for the crime. The evidence showed that Impe was an employee of the victim and had no motive to kill him, receiving a stable salary and tips. His timid and submissive character, as found by the trial court, explained his initial compliance with the appellants' invitation, but did not make him the sole perpetrator. The conspiracy and the actions of Gallego and Soriano in executing the plan were clearly established. On the penalty and indemnity: The Court affirmed the penalty of reclusion perpetua imposed by the trial court, as it was in accordance with the law for the crime of murder. However, the Court increased the indemnity to the heirs of Esteban Uy from P2,000 to P6,000, citing the doctrine laid down in People vs. Amansec, to conform with prevailing jurisprudence on the matter.
Main Doctrine
The Supreme Court affirmed the conviction of the appellants for murder, holding that their participation in the conspiracy to throw a hand grenade was sufficiently established by corroborating testimonies, and that alibi and claims of duress in extrajudicial confessions were not credible. The Court also modified the indemnity to P6,000 in line with established jurisprudence.