**Facts:**
1. On November 26, 1993, at around 7:30 AM, in Biñan, Laguna, Balwinder Singh, Dalvir Singh, Gurmok Singh, Jarnail Singh, Amarjit Singh, Mohinder Singh, Dial Singh, Kuldip Singh, Johander Singh Dhillon, and Malkit Singh Dhillon confronted Surinder Singh and demanded his presence.
2. Dalvir Singh attempted to stab Surinder Singh, narrowly missing, and commanded his companions to hold Surinder Singh.
3. Dial Singh and Johinder Singh restrained Surinder Singh, while Kuldip Singh pushed him forward. Dalvir Singh then successfully stabbed Surinder Singh in the stomach.
4. As Surinder Singh fell, Malkit Singh Dhillon and Jarnail Singh beat him with lead pipes, while Dial Singh and Johinder Singh punched and kicked him. Amarjit Singh prevented any assistance by brandishing a gun.
5. Dilbag Singh, who tried to intervene, was stabbed in the back by Balwinder Singh and narrowly avoided another attack by Gurmok Singh.
6. The assailants fled, leaving Surinder Singh mortally wounded. Both Dilbag Singh and Surinder Singh were taken to Perpetual Help Hospital where Surinder Singh was declared dead on arrival.
7. Dilbag Singh and witnesses informed the police and filed sworn statements leading to charges of homicide that were upgraded through reevaluation to murder and frustrated murder.
8. On January 7, 1994, the MTC upgraded the charges to “Murder” and “Frustrated Murder.”
9. On February 17, 1994, a prosecutor recommended charges only against Dalvir Singh for homicide and separately against Balwinder and Gurmok Singh for frustrated homicide.
10. Private complainants requested reinvestigation, resulting in murder and frustrated murder charges against all ten accused.
11. On September 23, 1994, three appellants pleaded not guilty, followed by Dalvir and Dial Singh’s arraignment on October 25, 1994.
12. Various procedural motions resulted in delays and adjustments, including changes in court venues.
13. Defense testimonies suggested a different event sequence, claiming self-defense, but this was not substantiated.
**Issues:**
1. Due process violations regarding procedural errors and irregularities during trial and preliminary investigation.
2. Credibility of the prosecution’s evidence versus the defense’s version of events.
3. Appropriateness of the imposed damages against the appellants.
**Court’s Decision:**
1. **Procedural Due Process:**
– The Court found that proper procedures were followed during the reinvestigation.
– The transfer motions and handling of bail were within judicial discretion and did not amount to denial of due process.
– Evidence presented during bail hearings was correctly considered at the trial.
2. **Evaluation of Evidence:**
– The Court upheld the trial court’s acceptance of the prosecution’s version. Appellants’ defenses of self-defense and procedural challenges were insufficient.
– The testimonies of private complainants were consistent and credible, demonstrating a concerted attack on both Surinder and Dilbag Singh.
3. **Damages:**
– The Court modified the monetary awards:
– Reduced Dilbag Singh’s medical expenses to exact proven costs and deleted attorney’s fees.
– Affirmed civil indemnity and moral damages for Surinder Singh’s heirs but adjusted other financial awards to align with proven expenses.
**Doctrine:**
– Compliance with procedural rules, including the automatic inclusion of bail hearing evidence in the main trial.
– The burden of proof in self-defense claims lies with the defendant, requiring clear and convincing evidence.
**Class Notes:**
– **Key Elements:**
– **Murder:** Includes intent to kill, unlawful killing, and qualified by treachery or premeditation.
– **Frustrated Murder:** The execution of sufficient acts towards killing, which did not result in death due to external intervention.
– **Conspiracy:** All participants are equally liable regardless of the extent of individual actions, the act of one is the act of all.
– **Statutes:**
– **Article 248, Revised Penal Code:** Defines and penalizes murder.
– **Article 250, Revised Penal Code:** Defines and punishes frustrated and attempted crimes.
– **Rules of Court, Rule 114, Section 8:** Burden of proving evidence strength in bail applications lies with the prosecution.
**Historical Background:**
– During the 1990s, Laguna, Philippines, witnessed increased criminal cases involving foreign nationals, often tied to business disputes and immigration issues. This case reflects underlying social tensions and the Philippine judiciary’s approach to handling complex multiculturally involved crimes.
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