Case 48

People vs Santos GR No. 127492

Facts:

On 1989, Valentino A. Guevarra was killed by four individuals who conspired to attack and assault him
with bolo and samurai weapons. Dionisio Santos was arraigned and tried, while Emmanuel Santos,
Emilio Santos, and Elizabeth Santos-Guerrero remain at large. Lucita Guevarra witnessed her son being
hacked by Dionisio Santos, and she tried to help but felt dizzy. Rodelio Dipana and another neighbor
witnessed the killing, but were killed by different attackers. Another neighbor, Ernesto del Rosario,
testified that Valentino was hacked by the accused at the back and on the right leg.
The prosecution witnesses' positive identification of Rodelio Dipana as one of the perpetrators of the
crime is not crucial to the prosecution's case. The appellant questions Rodelio Dipana's ability to identify
the accused as one of the perpetrators, as he stated he was not familiar with the assailants and did not
even report the incident to the authorities. The trial court correctly rejected the appellant's alibi, stating
that alibi is the weakest form of defense and without concrete evidence to back up the claim.
The appellant's alibi is self-serving and fails to establish the identity of the assailant.

Issue:

WON Santos is guilty of murder

Ruling:

Yes, lower courts judgement affirmed. The court found that the victim suffered a sudden and unexpected
attack, which was deliberate and severe, making it difficult for him to defend himself. The accused used
methods to ensure the execution of the offense without risking the offender's defense.
Case 49

People vs Pugay G.R. No. L-74324

Facts:

In 1982, two individuals, Pugay and Samson, conspired to kill a retardate Bayani Miranda in Rosario,
Cavite, Philippines. They poured gasoline on Miranda's body and set it on fire, causing his death. The
court found both accused guilty, but credited Pugay with the mitigating circumstance of lack of intention.
Pugay was sentenced to 12 years of prision mayor and 20 years of reclusion temporal, while Samson
suffered reclusion perpetua and accessories of the law for both. The accused-appellants appealed,
arguing that the court a quo had made errors, including not using the accused-appellants' statements,
suppressing evidence, and not lending credibility to Gabion's testimony. The court found the grounds for
the reversal of the decision to be without merit, and ruled that the criminal responsibility of Pugay and
Samson is individual and not collective.

Issue:

WON Pugay and Samson is guilty of Murder

Ruling:

No, only homicide. Giving him the benefit of doubt, it calls be conceded that as part of their fun-making
he merely intended to set the deceased's clothes on fire. No sufficient evidence appears in the record
establishing any qualifying circumstances, the accused Samson is only guilty of the crime of homicide
defined and penalized in Article 249 of the Revised Penal Code.
Case 50

People vs Guillermo GR No. 147786

Facts:

Eric G. Guillermo was charged with murdering his employer, Victor Francisco Keyser, in March 1998.
Keyser was the owner and manager of Keyser Plastic Manufacturing Corp., which shared its building with
Greatmore Corporation. Keyser's death was caused by a carpenter's saw being used to cut him into
pieces. Guillermo claimed that Keyser had been maltreating him and his co-employees and expressed no
regret about his actions. The police brought Guillermo to the Antipolo PNP Station for further
investigation, without informing him about his constitutional rights or providing him with counsel. The
National Bureau of Investigation (NBI) conducted a post-mortem examination on Keyser's remains,
finding that the head sustained thirteen contusions, abrasions, and other traumatic injuries. Dr. Ravell
Ronald R. Baluyot autopsied Keyser's remains, concluding that like a saw was likely used to mutilate the
corpse. The appellant contends that his conviction was based on inadmissible evidence, as there is no
clear showing that he was informed of his constitutional rights or made to understand them by the
police investigators. However, the Office of the Solicitor General (OSG) counters that the evidence clearly
shows that Guillermo admitted committing the crime in several instances, not just during the custodial
investigation.

Issue:

WON Guillermo is guilty of Murder

Ruling:

Yes, "outraging or scoffing at the corpse" is a qualifying circumstance. Dismemberment of a dead body is
one manner of outraging or scoffing at the corpse of the victim. The corpse of Victor F. Keyser was
dismembered by appellant who sawed off the head, limbs, and torso. This qualifying circumstance, when
it stated that the appellant "thereafter, cut into pieces using said saw one Victor F. Keyser." This being the
case, as proved by the prosecution, appellant is guilty not just of homicide but of murder.
Case 51

People vs (Umging) Umaguing G.R. No. L-52797

Facts:

Amparo Lazo y Villaflor, a septuagenarian woman with a stroke, was admitted to Polymedic General
Hospital in Manila on January 8, 1977. Anesthesiologist Doctor Estacio inserted an endotracheal rubber
tube into her mouth and windpipe for ventilation. Angelo Umaguing, a janitor, attempted to remove the
plaster holding the tube without justification, causing her to bleed and have a convulsion. The patient's
relatives transferred her to Cardinal Santos Hospital, where she died the next day due to
cardiorespiratory arrest. The Mandaluyong police secured statements from Jojo Cruz, Gloria Apostol,
Adelaida Apostol, and the nurse who pointed to Umaguing as the culprit. Umaguing was later convicted
of consummated murder. His counsel admitted that he removed the endotracheal tube and did not
execute any sworn statement to prove his innocence. The Solicitor General recommended the acquittal
of Umaguing on the grounds that the proximate cause of the patient's death was cardio-respiratory
arrest and that it was not shown that the accused acted with criminal intent.

Issue:

WON Umaguing the Janitor is guilty of murder

Ruling:

No, only attempted murder. He was not able to perform all the acts of execution necessary to
consummate the crime because the victim was transferred to another hospital and the accused was
immediately apprehended. Umaguing, as a janitor, had nothing to do with the patient. He had no
business being in the emergency room at eight o'clock in the evening. As his act of removing the tube
was wrongful, it is to be presumed that he did so with an evil intent.
Case 52

People vs Dela Cruz, et al. G.R. No. 148730

Facts:

On 1999, a passenger bus carrying Chinese-Filipino Friendship Transport, Inc. (CFFTI) passengers was
robbed by a group of accused-appellants, including Jose dela Cruz, James Salboro, Edwin "Butch" Gener,
Arnel San Pedro, and three unidentified companions. The bus was driven by Terry Edma and Antonio
Dormitorio, who were victims of the holdup. Detectives from the CIDG invited Edma and Dormitorio to
identify the suspects in the robbery-homicide incident. They positively identified three suspects: Jose
dela Cruz, James Salboro, Arnel San Pedro, and Edwin "Butch" Gener. The accused-appellants raised the
defense of denial and alibi, claiming they had not known each other individually prior to their arrest.
However, the trial court found no reason to set aside the conviction of the accused-appellants, as the
evidence on record revolved around the question of credibility of witnesses. The prosecution witnesses,
Terry Edma and Antonio Dormitorio, positively identified the accused-appellants as among those
responsible for the bus robbery and the killing of police officer Ebona. Robo con homicidio is an
indivisible offense with a severe penalty, as it places lucre above the value of human life. In this case, all
essential ingredients of robbery with homicide have been established by the prosecution with proof
beyond reasonable doubt.

Issue:

WON their defense of not knowing each other and was in different place at the time of the commission
of offense is tenable

Ruling:

No, still guilty of robbery with homicide. Having been properly identified by the other victims of robbery,
and the houses where they claim where they are at that time is in near the crime scene. Homicide takes
place by reason or on the occasion of the robbery, all those who took part in the robbery shall be guilty
of the special complex crime of robbery with homicide whether or not they actually participated in the
killing, unless there is proof that they had endeavored to prevent the perpetration of the crime