Ingal vs People of the Philippines

547 SCRA 632

FACTS:
-9pm of March 2, 1987, Rolando N. Domingo (Toto) was eating at the carinderia together with his
female companion. When a man, went up to him and stabbed him and left as if nothing happened.
-The event was witnessed by Aida Bona (owner of the carinderia), Rosalinda Tan (helper in the
carinderia). They gave a Sinumpaang Salaysay but declined to sign it not unless the suspects were
apprehended. They agreed to be a witness on the case, 7 years after the crime happened. They said that
it was only Joseph Ingal who did the crime.
-Several witnesses claimed that there were actually 4 who were part of the crime. Two, who are
unknown up to this date, one is Ingal and the other one is Ricardo Lidot. Witnesses claim that Lidot
handed the weapon to Ingal. Having 4 suspects is contrary to the claims of Bona and Tan.
-Ingals claim was that he was at his work during the crime delivering fish at Navotas.
-There was conspiracy involved with Ingal, Lidot and two other unknown persons. However, conspiracy
is not an element of crime of murder or homicide. Conspiracy assumes pivotal importance in the
determination of the liability of the perpetrators. Thus, if the evidence adduced by the prosecution fails
to prove conspiracy, only those whose liability can be established can be held liable for the crime
charged. It is proven that Ingal was the one who stabbed Toto. But since conspiracy was not shown in
the case, the other accused cannot be convicted because their respective liabilities were not
satisfactorily proven.
-Treachery attended the killing because of the sudden and unexpected attack.
-premeditation of the crime could not be proved by the prosecution.
ISSUE:
Is Ingal criminally liable for the death of Rolando Domingo? Is there conspiracy? Is Lidot liable for the
crime?
HELD:
1. Yes, it was evident from the witnesses that it was Ingal who stabbed Toto with the intention to
kill him, and he succeeded.
2. Yes, but it could not be proven by the prosecution.
3. Yes, he is liable for the crime. He is guilty without reasonable doubt for the murder as defined in
Article 248 of the Revised Penal Code, qualified by treachery. He is to suffer reclusion perpetua.
He is ordered to pay the heirs of Toto the amount of P50,000 as civil indemnity, P50,000 as
moral damages, P25,000 as temperate damages and P25,000 as exemplary damages.