People vs. Patrolla Jr.

G.R. No. 112445 (March 7, 1996)

Carlos Patrolla, Jr. was convicted of murder; guilty pleas in conspiracy don’t exonerate others.

Facts:

Carlos Patrolla, Jr. and his brother Alex were charged with murder and less serious physical injuries for the violent attack on spouses Nido and Belinda Panogalinog on September 28, 1991, in San Carlos City, Negros Occidental. The amended information detailed that both accused, armed with bolos, conspired to kill Nido and inflicted serious injuries on him, resulting in his death, while also causing less serious injuries to Belinda.

During the incident, the brothers approached the Panogalinogs at their barbecue stand. Carlos stabbed Nido multiple times while Alex inflicted injuries on Belinda. Witnesses, including Belinda, testified that the brothers worked in concert to prevent Nido from escaping, ultimately leading to his fatal injuries. Nido was pronounced dead shortly after the attack due to shock from severe hemorrhage caused by the stab wounds.

Upon arraignment, both accused pleaded not guilty. However, during pre-trial, Alex pleaded guilty to homicide, which led to his conviction and sentencing. The trial continued against Carlos, who maintained his innocence.

Legal Issues:

  1. Whether Carlos Patrolla, Jr. was guilty beyond reasonable doubt of murder and less serious physical injuries.
  2. The implications of Alex Patrolla's guilty plea to homicide on Carlos's culpability.
  3. The validity of Carlos's defense of alibi.
  4. The proper classification of the crime and the corresponding penalties.

Arguments:

  • For the Prosecution: The prosecution argued that Carlos and Alex conspired to commit murder, as evidenced by their coordinated attack on Nido. The prosecution maintained that treachery was present, as the attack was sudden and left Nido with no chance to defend himself. Witness testimonies corroborated the prosecution's claims of conspiracy and the brutal nature of the attack.

  • For the Defense: Carlos contended that he was not guilty of murder, asserting that Alex's guilty plea indicated he alone was responsible for the crime. He also claimed an alibi, stating that he was at home with his parents during the time of the incident, which was supported by his father's testimony.

Court's Decision and Legal Reasoning:

The trial court found Carlos guilty of murder and less serious physical injuries, sentencing him to reclusion perpetua for the murder and a month of arresto mayor for the injuries inflicted on Belinda. The court reasoned that Alex's guilty plea did not absolve Carlos of liability, as it did not imply sole authorship of the crime. The evidence presented showed a clear conspiracy between the brothers, with both actively participating in the attack.

The court also upheld the presence of treachery, noting that the attack was premeditated and executed in a manner that ensured Nido could not defend himself. The defense of alibi was rejected, as the positive identification of Carlos by witnesses outweighed his father's vague testimony.

The court acknowledged that the trial court erred in convicting Carlos of two separate crimes arising from a single act. It clarified that the correct classification was a complex crime of murder with less serious physical injuries, leading to the imposition of a single penalty of reclusion perpetua.

Significant Legal Principles Established:

  1. A guilty plea by one co-accused does not automatically exonerate another co-accused from criminal liability.
  2. The presence of treachery can qualify a killing as murder, particularly when the attack is sudden and leaves the victim unable to defend themselves.
  3. Alibi is a weak defense that cannot prevail against positive identification by witnesses.
  4. When a single act results in multiple offenses, the penalty for the most serious crime shall be imposed in its maximum period, as per Article 48 of the Revised Penal Code.