People vs. Salison

G.R. No. 115690 (February 20, 1996)

Facts:

Accused-appellant Rey Salison, Jr., along with three co-accused, was charged with the murder of Rolando Valmoria, who died from injuries sustained during an altercation on November 30, 1990, in Davao City. The information alleged that the accused conspired to attack Valmoria, using pieces of wood to inflict serious injuries. Valmoria was initially treated for his injuries but succumbed to them four days later.

During the trial, the prosecution presented seven witnesses, including eyewitnesses who testified to the events leading to Valmoria's death. Witnesses described how Salison initiated the confrontation by boxing Valmoria and how the other co-accused joined in the assault. The victim, after being attacked, managed to escape to his home but later sought medical attention due to severe pain and dizziness. A written declaration made by Valmoria, stating the identities of his assailants, was presented as evidence, along with medical records confirming the cause of death as a result of blunt force trauma.

Salison, in his defense, denied involvement in the murder, claiming he was not present during the attack and suggesting that the victim was engaged in a fistfight with his co-accused. He did not present any corroborating evidence to support his alibi.

Legal Issues:

1. Whether the trial court erred in finding that there was proof beyond reasonable doubt of conspiracy among the accused in the commission of the crime.
2. Whether the accused should only be held responsible for the injuries he personally inflicted on the victim.
3. Whether the trial court erred in admitting the victim's "dying declaration" and the written agreement between the parents of the accused and the victim.

Arguments:

• Prosecution's Arguments:

  • The prosecution argued that the testimonies of multiple eyewitnesses clearly established the conspiracy and collective action of the accused in attacking Valmoria. The evidence included the victim's dying declaration, which identified the assailants and detailed the circumstances of the attack.
  • The prosecution maintained that the nature of the assault, involving multiple attackers and the use of blunt objects, demonstrated a clear intent to kill, thus justifying the charge of murder.

• Defense's Arguments:

  • The defense contended that the evidence did not sufficiently prove conspiracy, asserting that Salison should only be liable for any injuries he personally inflicted.
  • The defense also challenged the admissibility of the dying declaration, arguing that it was not made under the consciousness of impending death and that it was written in a regional language without a proper translation.

Court's Decision and Legal Reasoning:

The court affirmed the trial court's decision, finding Salison guilty of murder. The court held that the testimonies of the prosecution witnesses were credible and consistent, establishing Salison's direct participation in the attack. The court emphasized that the presence of multiple assailants and the use of weapons indicated a conspiracy, as all accused acted in concert to inflict harm on the victim.

Regarding the dying declaration, the court ruled that the defense had waived any objection to its admissibility by failing to raise the issue during the trial. The court noted that the declaration was made shortly after the incident while the victim was in significant pain, which supported its admissibility as a dying declaration or as part of the res gestae.

The court also clarified that conspiracy does not require direct evidence of prior agreement; it can be inferred from the actions of the accused during the commission of the crime. The court concluded that all conspirators are liable for the acts committed in furtherance of their common purpose, regardless of who delivered the fatal blow.

Significant Legal Principles Established:

1. Conspiracy in Criminal Law: Conspiracy can be inferred from the actions of the accused during the commission of a crime, and all conspirators are liable for the acts committed in furtherance of their common purpose.
2. Dying Declarations: A dying declaration is admissible if made under the belief of impending death, and the failure to object to its admissibility can result in a waiver of any claims regarding its validity.
3. Collective Responsibility: In cases of collective aggression, the actions of one conspirator can be attributed to all, establishing shared liability for the crime committed.