People v. Macabuhay
REITERATIONFacts
The Antecedents: Early in the evening of March 16, 1947, in Basey, Samar, Fidel Saborrido was killed by Gorgonio Macabuhay. Prior to the incident, the victim was in the house of Alfredo Aclesto, enjoying a song feast with others. Meanwhile, the five accused were making pilipig at a nearby residence when a stone was thrown, narrowly missing Perfecto Bacasno. Suspecting the culprit was at Aclesto's house, the accused proceeded there. Procedural History: The Court of First Instance of Samar convicted the five appellants of murder and sentenced them to life imprisonment, ordering them to indemnify the victim's heirs. The case was appealed to the Supreme Court. The Appeal: The defendants-appellants contested their conviction for murder. Their defense involved denials of participation and, in the case of Gorgonio Macabuhay, a claim of self-defense. The prosecution, however, presented evidence and testimonies that established a common motive and collective action among the accused, leading to the victim's death.
Issue(s)
Whether the appellants, other than Gorgonio Macabuhay who admitted inflicting the wound, are criminally liable for the murder of Fidel Saborrido. Whether the claim of self-defense by Gorgonio Macabuhay is tenable. Whether the penalty imposed by the trial court is in accordance with law.
Ruling
The Supreme Court affirmed the conviction of all five appellants for murder. The penalty imposed by the trial court was affirmed, with a modification for Gorgonio Macabuhay to have his sentence mitigated due to being less than eighteen years old at the time of the offense. The judgment was affirmed in all other respects.
Ratio Decidendi
On Whether the appellants, other than Gorgonio Macabuhay, are criminally liable for the murder of Fidel Saborrido: The Court ruled in the affirmative. Evidence showed that all accused were animated by one motive: to avenge the stone-throwing incident. They proceeded to the victim's house for a confrontation and simultaneously attacked Fidel Saborrido in pursuance of this common purpose. Therefore, all and each of them were considered the cause of his untimely demise. The Court cited previous decisions in parallel situations supporting this view, emphasizing that the collective action and common motive established conspiracy and shared liability. On Whether the claim of self-defense by Gorgonio Macabuhay is tenable: The Court found the claim of self-defense to be untenable. Gorgonio Macabuhay testified that he killed Saborrido because the latter had boxed him twice. However, he failed to explain how and why the quarrel took place, and his tale of self-defense was not corroborated by any witness. This lack of corroboration and explanation weakened his claim, especially when contrasted with the prosecution's version of events. On Whether the penalty imposed by the trial court is in accordance with law: The Court found the penalty of life imprisonment imposed by the trial court to be in accordance with Article 248 of the Revised Penal Code. However, the Court agreed with counsel that Gorgonio Macabuhay was entitled to mitigation because he was less than eighteen years old when he committed the offense. Consequently, his term of imprisonment was fixed at not less than fourteen (14) years and eight (8) months and not more than twenty (20) years. The appealed judgment was affirmed in all other respects.
Main Doctrine
The Supreme Court affirmed the conviction of the appellants for murder, holding that all accused were responsible for the killing of Fidel Saborrido. The Court found that the appellants, motivated by a common purpose to avenge a prior incident of stone-throwing, collectively attacked the victim. The decision emphasizes that even if one accused directly inflicted the fatal wound, all who participated in the conspiracy and assault are liable for the crime.