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**Facts:**
On April 25, 1996, at around 3:30 PM, Jaime Lopez, Rogelio Regalado, and Romeo Aragon attacked Edencito Chu (Bonjong) in Hinatuan, Surigao del Sur. The incident began when Regalado confronted Chu outside Bantogan Tailoring, provoking Chu, who then asked for forgiveness while placing his arm around Regalado. Regalado responded by stabbing Chu below the left nipple. Chu ran, but Regalado chased and hit him with firewood. Lopez and Aragon joined the chase; Aragon boxed and kicked Chu, causing him to fall, while Lopez knifed Chu multiple times. Chu died before reaching the hospital.
Post-mortem examinations described fatal stab wounds and lacerations across Chu’s body, inflicted by sharp instruments. The defense presented varying accounts, including claims of self-defense and defense of a relative from Lopez, and an alibi from Aragon.
Procedurally, the case moved through the Regional Trial Court (RTC) of Surigao del Sur which convicted the trio of murder, attributing conspiracy, treachery, and the use of superior strength. The appellants contested this decision at the Court of Appeals, which upheld the RTC ruling. The present appeal brought the case to the Supreme Court.
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**Issues:**
1. Whether conspiracy attended the killing of the victim.
2. Whether the RTC erred in not considering the defenses interposed by the accused-appellants (self-defense, defense of relative, and alibi).
3. Whether the RTC correctly convicted the accused-appellants of murder under Article 248 of the Revised Penal Code.
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**Court’s Decision:**
**1. Conspiracy:**
The Supreme Court affirmed the existence of conspiracy. Evidence supported that the appellants cooperated with the shared intent to kill Chu. Regalado initiated the attack by stabbing Chu, who then fled but was pursued and assaulted by all three accused. The coordinated actions, such as Regalado’s repeated hitting and Lopez’s multiple stab wounds, signaled a common design to murder Chu.
**2. Defense Considerations:**
– **Self-defense (Lopez):** The Court dismissed Lopez’s claim, establishing that Chu’s act of chasing Regalado, even if aggressive, ceased when Lopez stabbed Chu multiple times, reflecting overreaction rather than protection.
– **Defense of Relative (Lopez):** The Supreme Court highlighted the absence of imminent unlawful aggression from Chu when Lopez caught up, thus invalidating the defense. The extreme response of Lopez was ruled excessive and unwarranted.
– **Alibi (Aragon):** Aragon’s claim of being at the wharf was discredited. Proximity to the crime scene, coupled with eyewitness identification, weakened his defense.
**3. Murder Conviction:**
The Court upheld the appellants’ conviction for murder, stressing the presence of treachery. The sudden attack by Regalado while Chu sought forgiveness, coupled with subsequent collective aggression, exemplified treachery as Chu was incapable of defending himself.
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**Doctrine:**
– **Conspiracy in Murder:** Coordinated acts demonstrating a shared intent to commit a crime will be construed as conspiracy.
– **Treachery:** Deliberate surprise attacks leaving the victim defenseless qualify as treachery, heightening liability to murder.
– **Defenses in Homicide:** Claims of self-defense and defense of relatives require imminent and reasonable threats, excluding excessive retaliations. Alibis must establish impossibility of presence at the crime scene.
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**Class Notes:**
– **Elements of Conspiracy:** Common criminal intent; participation in execution.
– **Self-defense requirements:** Unlawful aggression, reasonable necessity, no provocation.
– **Article 248 (Revised Penal Code):** Defines and penalizes murder, emphasizing aggravating circumstances like treachery.
– **Treachery criteria:** Suddenness of attack, inability of victim to defend, severity of attack.
– **Alibi:** Physical impossibility of presence at the crime scene, corroborated by credible evidence.
Relevant Statute: Article 248, Revised Penal Code – “Murder is committed by any person who, not falling within the provisions of Article 246, shall kill another, attended by any of the following attendant circumstances: …employing means of treachery…”
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**Historical Background:**
The case studies the socio-legal dynamics in rural Philippines, casting light on typical street violence and the implementation of justice in lower courts influenced by local conditions—critical in understanding the principles behind murder trials and judicial collaboration in understanding aggressive, coordinated attacks. This case underscores judicial insistence on meticulous establishment of conspiracy and treachery to affirm murder convictions.
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