**People of the Philippines vs. Conrado M. Glino: A Case of Murder and Less Serious Physical Injuries Stemming from a Jeepney Altercation**
### Facts:
On November 15, 1998, in Moonwalk, Las Piñas City, Domingo Boji and his wife Virginia were passengers in a jeepney bound for Alabang-Zapote Road. Accused-appellant Conrado Glino, who was drunk, boarded the jeepney and took a seat next to Virginia Boji. Glino’s actions including leaning on Virginia’s shoulder prompted confrontations, first from Virginia and then from her husband Domingo.
The situation escalated when the jeepney neared Casimiro Village. Marvin Baloes, Glino’s companion, told the driver they were alighting. Instead, Baloes stabbed Domingo with an improvised knife, followed by Glino who used a Batangas knife, leading to Domingo’s death and Virginia sustaining incised wounds on her fingers while trying to protect her husband.
Glino and Baloes attempted to flee but were apprehended by traffic enforcers Alvin Cristobal and Ruben Ramirez with assistance from a concerned motorist. Virginia and Domingo Boji were rushed to a medical center where Domingo was pronounced dead.
Conrado Glino and Marvin Baloes were indicted for murder and attempted murder. With Baloes’ death due to cardio-pulmonary arrest in detention, the proceedings concentrated on Glino. The prosecution relied on testimonies from co-passenger Enrique Villaruel, Virginia Boji, investigator SPO2 Wilfredo Dalawangbayan, and traffic aide Alvin Cristobal. Glino, denying involvement, was identified by witnesses as one of the attackers.
### Issues:
1. Whether the trial court erred in convicting Glino despite Virginia Boji’s admission that she did not see Glino stab her husband.
2. Whether Glino can be deemed guilty of homicide and attempted homicide only, lacking the qualifying circumstance of treachery.
### Court’s Decision:
The Supreme Court (SC) affirmed Glino’s conviction for murder concerning the death of Domingo Boji, recognizing the presence of treachery and conspiracy between Glino and Baloes. The SC modified the lower courts’ rulings regarding Virginia Boji, convicting Glino of less serious physical injuries instead of attempted murder due to the absence of a clear intent to kill Virginia.
### Doctrine:
The SC reiterated the doctrine on the assignment of values to witness testimonies, emphasizing the trial court’s advantage in observing witness demeanor. It also clarified the principles of conspiracy, wherein the conduct of accused individuals indicating a common understanding to commit a crime suffices to establish conspiracy, rendering each actor in conspiracy equally guilty regardless of who delivered the fatal blows.
### Class Notes:
– **Conspiracy** in criminal cases implies that the act of one conspirator is deemed the act of all; it does not require a formal agreement.
– **Treachery** is present when the attack ensures the victim has no opportunity for defense or retaliation, making the crime more grievous.
– **Physical Injuries** can be categorized into slight, less serious, or serious, based on factors like medical attendance duration and incapacitation period.
– **Principle of Variance**: An accused can be convicted of the offense proved that is necessarily included in the offense charged if the facts show that the lesser offense is committed.
### Historical Background:
This case underscores the dangers posed by drunk passengers in public conveyances, prompting the SC to suggest legislative action. It reflects societal concerns regarding public safety and the criminal justice system’s adaptability in addressing unforeseen situations not explicitly covered by existing laws.
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