People v. Cabiles

G.R. No. 115216 (July 5, 1996)

Facts:

Accused-appellant David Cabiles, Sr., along with his sons David, Jr., William, and Nolito (alias "Lito"), were charged with the murder of Constancio Demesa, Jr. The incident occurred on July 19, 1991, in Sitio Balyong Tulay, Brgy. Caranan, Pasacao, Camarines Sur. The Information alleged that the accused conspired to kill Demesa, using stones, a spear, and bolos, resulting in multiple fatal injuries that caused his instantaneous death.

During the trial, only David Cabiles, Sr. was present as the other accused remained at large. The prosecution presented several witnesses, including barangay officials and family members of the victim, who testified about the events leading to the attack. Witnesses stated that an argument ensued between Cabiles, Sr. and Demesa, during which Cabiles, Jr. threw stones at Demesa, and William stabbed him with a spear. The witnesses described how the accused surrounded Demesa and attacked him collectively, leading to his death.

The autopsy conducted by Dr. Melchor Baesa revealed that Demesa sustained fourteen injuries, eleven of which were stab wounds. The cause of death was determined to be cardiac respiratory arrest due to the inflicted wounds.

David Cabiles, Sr. pleaded not guilty and claimed self-defense, asserting that Demesa was the unlawful aggressor. However, the prosecution's witnesses consistently testified that Demesa was unarmed during the confrontation.

Legal Issues:

1. Whether the trial court erred in disregarding the claim of self-defense by the accused-appellant.
2. Whether the trial court erred in convicting the accused of murder despite the alleged justifying circumstances.
3. Whether the trial court denied the accused-appellant's right to procedural due process by not allowing a witness to testify.

Arguments:

For the Accused-Appellant:

• The accused-appellant argued that Demesa was the unlawful aggressor, claiming he was armed with a balisong and initiated the confrontation.
• He contended that the wounds inflicted on Demesa were in self-defense and that the trial court failed to consider mitigating circumstances.
• The accused-appellant also claimed that the trial court erred in denying his motion to postpone the case to allow Dr. Sy to testify about the injuries sustained by his son William during the incident.

For the Prosecution:

• The prosecution maintained that the evidence clearly showed that Demesa was unarmed and did not pose an imminent threat when he was attacked.
• Witness testimonies indicated that the accused acted in concert to kill Demesa, demonstrating conspiracy and treachery.
• The prosecution argued that the elements of murder were present, including the intent to kill and the qualifying circumstance of treachery.

Court's Decision and Legal Reasoning:

The court affirmed the trial court's decision, finding that the prosecution had proven beyond a reasonable doubt the guilt of David Cabiles, Sr. for the crime of murder. The court ruled that the claim of self-defense was not substantiated, as the testimonies of the prosecution witnesses contradicted the accused's assertions of unlawful aggression. The court emphasized that for self-defense to be valid, there must be an actual, sudden, and unexpected attack, which was not present in this case.

The court also noted that the presence of conspiracy among the accused was evident, as they acted together to attack Demesa. The court reiterated that the act of one conspirator is the act of all, making all accused equally liable for the murder.

Regarding the procedural due process claim, the court found that the accused-appellant was given ample opportunity to present his case and that the proposed testimony of Dr. Sy was irrelevant to the self-defense claim.

Significant Legal Principles Established:

• The requirements for self-defense include the presence of unlawful aggression, reasonable necessity of the means employed, and lack of sufficient provocation.
• Conspiracy can be inferred from the acts of the accused, and all conspirators are liable for the acts committed in furtherance of the conspiracy.
• The act of one conspirator is considered the act of all, regardless of individual participation levels.