In the case of *People of the Philippines vs. Filomeno Barnuevo, Demetrio Palacat, and Teresito Sabalza*, the Supreme Court affirmed the conviction of the accused for murder, reinforcing the principle that when individuals act in concert with a common purpose to commit a crime, each is equally responsible for the resulting offense, regardless of the specific actions each performed. This decision underscores the importance of establishing conspiracy in determining criminal liability, especially when multiple individuals are involved in a single act of violence, and clarifies the conditions under which self-defense or defense of relatives may be invoked as a valid justification.

When Brotherhood Becomes Bloodshed: Examining Conspiracy in a Fatal Brawl

The facts of the case reveal a grim scenario that unfolded on the evening of December 2, 1983, in Barangay Sta. Fe, Abuyog, Leyte. Leopoldo Nacman was attacked by Filomeno Barnuevo, Demetrio Palacat, and Teresito Sabalza. The prosecution presented eyewitnesses who testified that Filomeno and Teresito boxed and kicked Leopoldo, while Demetrio stabbed him multiple times with a Batangas knife. Leopoldo succumbed to his injuries several days later. The accused were charged with murder, with the prosecution arguing that their actions were premeditated and executed with treachery and abuse of superior strength.

In contrast, the defense attempted to portray the events as a case of self-defense or defense of a relative. Demetrio claimed that he acted in defense of his brother-in-law, Filomeno, who was allegedly attacked first by Leopoldo. He argued that Leopoldo had drawn a knife and was about to stab Filomeno when he, Demetrio, intervened and, in the ensuing struggle, stabbed Leopoldo in self-defense. The defense also presented witnesses who testified that Leopoldo was the initial aggressor. The trial court, however, found the testimonies of the prosecution witnesses more credible and convicted the accused of murder.

The Court of Appeals upheld the trial court’s decision, increasing the penalty and the indemnity awarded to the victim’s heirs. The case was then elevated to the Supreme Court, where the central issue revolved around the credibility of the witnesses and the applicability of the defense of a relative. The appellants argued that the Court of Appeals should have appreciated the justifying circumstance of defense of a relative in favor of Demetrio, as he was purportedly defending Filomeno from Leopoldo’s unlawful aggression. They further contended that the testimonies implicating Filomeno and Teresito should be disregarded, given Demetrio’s admission that he was the one who stabbed Leopoldo.

The Supreme Court, however, affirmed the findings of the lower courts, emphasizing the importance of the trial court’s assessment of the witnesses’ credibility. The Court noted that the prosecution witnesses provided clear and consistent accounts of the events leading to Leopoldo’s death. Moreover, the defense failed to present any evidence to suggest that the prosecution witnesses had any motive to fabricate their testimonies. The Supreme Court reiterated the well-established principle that the trial judge is in the best position to assess the credibility of witnesses, as they have the opportunity to observe their demeanor and manner of testifying.

Regarding Demetrio’s claim of defense of a relative, the Supreme Court reiterated the elements necessary to invoke this justifying circumstance, specifically, that there must be an unlawful aggression by the victim. Moreover, the means employed to prevent or repel the unlawful aggression must be reasonable, and that in case the provocation was given by the person attacked, the one making the defense must have no part therein. The court found that the defense failed to prove unlawful aggression on the part of Leopoldo. In fact, the court found that the presence of several stab wounds on the body of the victim, four of them fatal, negated the claim that the killing was justified, which instead indicated a determined effort to kill the victim.

Equally known and well understood by now are the requirements in order for defense of relative to be appreciated. The accused must prove that there was unlawful aggression by the victim, that the means employed to prevent or repel the unlawful aggression was reasonable, and that in case the provocation was given by the person attacked, the one making the defense must have no part therein.

Furthermore, even assuming that Leopoldo initiated the attack, the Court noted that the aggression had ceased when the appellants wrested the knife from him and he fell to the ground. The fact that the appellants continued to inflict blows on Leopoldo even after he was subdued indicated that they had become the unlawful aggressors. This demonstrates a critical point in self-defense and defense of relatives: the defense is no longer justified once the initial aggression has ceased, and any further violence becomes an act of retaliation rather than protection.

Turning to the liability of Filomeno and Teresito, the Supreme Court emphasized the existence of a conspiracy among the three accused. The Court explained that in a conspiracy, it is not necessary to show that all the conspirators actually participated in the act of killing the victim. What matters is that they acted in concert, with a common purpose or design to bring about the death of the victim. The Court highlighted that conspiracy may be proven through circumstantial evidence or inferred from the acts of the accused themselves.

In a conspiracy, it is not necessary to show that all the conspirators actually hit and killed the victim. What is important is that all the participants performed specific acts with such closeness and coordination as to unmistakably indicate a common purpose or design to bring about the death of the victim.

In this case, the Court found that Filomeno and Teresito’s actions of boxing and kicking Leopoldo while Demetrio stabbed him demonstrated a unity of purpose to kill Leopoldo. This concerted action established their liability as co-conspirators, making them equally responsible for Leopoldo’s death. This aspect of the ruling underscores the principle that those who participate in a conspiracy are held accountable for the collective actions of the group, even if their individual contributions to the crime are different. Moreover, the Court pointed out that the killing was attended by abuse of superior strength. Leopoldo was alone and unarmed when attacked by the three appellants, one of whom was armed with a knife. This disparity in strength and means further justified the conviction for murder, as the appellants took advantage of their superior position to ensure the success of their criminal act.

Therefore, the Supreme Court held that the crime committed by the three accused-appellants was murder, punishable by *reclusion perpetua*. The Court also affirmed the Court of Appeals’ decision to increase the indemnity awarded to the victim’s heirs from P30,000 to P50,000, in line with current case law. Furthermore, the Court ordered the appellants to pay the victim’s heirs P176,000 as indemnity for the deceased’s loss of earning capacity, calculated based on his age, income, and life expectancy.

The formula repeatedly adopted by the Court is as follows:

FAQs

The ruling in *People vs. Barnuevo* serves as a clear reminder of the legal consequences of participating in a criminal conspiracy and the limitations of self-defense claims. The decision reinforces the principle that individuals who act together with a common criminal purpose are equally responsible for the resulting harm, regardless of their specific roles in the commission of the crime. Moreover, it highlights the importance of ensuring that any defensive actions taken are proportionate to the threat and cease once the initial aggression has ended.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: People of the Philippines, vs. Filomeno Barnuevo, G.R. No. 134928, September 28, 2001