People v. Medice

G.R. No. 181701 (January 18, 2012)

Nestor Medice was sentenced to reclusion perpetua for conspiracy to murder Garry Ruiz.

Facts:

On May 18, 2001, Nestor Medice and Eduardo Dollendo were accused of murder in Criminal Case No. C-2971 before the Regional Trial Court in Catarman, Northern Samar. During the arraignment, Medice pleaded not guilty, while Dollendo had escaped from custody and was not present for the trial. The prosecution's case was based on the testimonies of several witnesses, including Mylene Ruiz, the wife of the victim Garry Ruiz, and eyewitnesses Deolito Romines and Joseph del Valle.

Mylene Ruiz testified that on February 10, 2001, both accused visited her home looking for her husband, indicating they had a problem with him. On February 13, 2001, at approximately 2:30 PM, Garry Ruiz was killed at Romines' house in Barangay West, San Jose, Northern Samar. Eyewitnesses Romines and del Valle recounted that Ruiz was playing cards with friends when Medice and Dollendo entered the house. Medice handed a bolo (a type of knife) to Dollendo, who then stabbed Ruiz multiple times, resulting in his death shortly thereafter.

Dr. Norma E. Dato, the Municipal Health Officer, conducted an autopsy and confirmed that Ruiz died from stab wounds that injured vital organs, including the heart and lungs. The trial court found Medice guilty of murder on April 30, 2003, sentencing him to reclusion perpetua and ordering him to pay damages to the victim's heirs.

Medice appealed the decision, and the Court of Appeals affirmed the trial court's ruling on November 28, 2006, leading to further appeal to the Supreme Court.

Legal Issues:

  1. Whether the prosecution established the elements of murder, including the presence of treachery.
  2. Whether the defense of alibi presented by Medice was sufficient to exonerate him from the charges.
  3. Whether there was a conspiracy between Medice and Dollendo to commit murder.

Arguments:

Prosecution:

  • The prosecution argued that Medice was guilty of murder as he was a principal by induction. They presented eyewitness accounts that established Medice's involvement in the crime, specifically that he provided the weapon and facilitated the attack.
  • They asserted that the killing was attended by treachery, as the attack was sudden and the victim had no opportunity to defend himself.

Defense:

  • Medice's defense was primarily based on an alibi, claiming he was at a friend's house during the time of the murder, which was only 40 meters away from the crime scene.
  • The defense contended that there was insufficient evidence to prove conspiracy and that Medice did not directly participate in the stabbing.

Court's Decision and Legal Reasoning:

The Supreme Court affirmed the conviction of Medice, holding that the prosecution had sufficiently established the elements of murder. The Court found that:

  1. Treachery: The attack was sudden and unexpected, leaving the victim with no chance to defend himself. The testimonies of the eyewitnesses confirmed that the victim was unaware of the impending attack.

  2. Conspiracy: The Court ruled that Medice's actions demonstrated a conspiracy to commit murder. His involvement in fetching Dollendo and providing the weapon indicated a collective intent to kill, making him equally liable despite not delivering the fatal blows.

  3. Alibi: The Court rejected the defense of alibi, noting that it was not physically impossible for Medice to be at the crime scene given the proximity of the locations. Furthermore, the positive identification of Medice by witnesses undermined his alibi.

The Court also addressed the penalties, affirming the imposition of reclusion perpetua and the award of civil indemnity, moral damages, temperate damages, and exemplary damages to the victim's heirs.

Significant Legal Principles Established:

  • The presence of treachery can qualify a killing as murder even if not explicitly stated in the information.
  • Conspiracy can be established through circumstantial evidence, and all conspirators are liable for the acts committed in furtherance of the conspiracy.
  • The defense of alibi must demonstrate physical impossibility to be at the crime scene, which was not established in this case.