327 Cases Penned by Associate Justice Amy Lazaro-Javier: 2025 Bar Examination
Could one be convicted of murder, yet later be convicted
only of homicide due to lack of treachery?
People of the Philippines v. Aries Reyes y Hilario, Argie
Reyes y Hilario, Arthur Hilario, and Demetrio Sahagun y Manalili
G.R. No. 227013 | June 17, 2019
Facts of the Case:
On August 5, 2007, in Quiapo, Manila, Jun Balmores had an
altercation with the Reyes brothers over the refusal to store his mother's
goods in their stall. Later that day, as Balmores retrieved his belongings,
Aries Reyes, Demetrio Sahagun, Argie Reyes, and Arthur Hilario pursued and
attacked him. Demetrio struck Balmores with a plastic chair, causing him to
fall, while Aries and Arthur beat him with broomsticks. Though Balmores managed
to flee, Argie caught up with him and stabbed him twice, causing his death.
The accused, Aries Reyes and Demetrio Sahagun, were
convicted of murder by the Regional Trial Court (RTC) in a decision dated
August 27, 2014. The court found that treachery and abuse of superior strength
attended the killing. They were sentenced to reclusion perpetua without
eligibility for parole. The court ordered them to pay civil indemnity, moral
damages, and actual damages for funeral and burial expenses.
The Court of Appeals affirmed the trial court's decision on
March 10, 2016, but modified the awards for damages.
The defense maintained that they were not involved in the
killing, claiming that they were playing cards when the stabbing occurred. They
argued that the murder was committed solely by Argie Reyes after a scuffle with
Balmores. Nevertheless, the courts found their testimony unconvincing.
Primary Issue:
Did the Court of Appeals err in affirming the accused's
conviction for murder despite their defense of non-complicity and the absence
of qualifying circumstances?
Supreme Court Decision:
The Supreme Court reversed the conviction for murder and
found the appellants guilty only of homicide. While the victim was killed, and
the accused participated in the crime, the Court ruled that treachery was not
present. The killing appeared to have been triggered by a spontaneous argument,
and Balmores had the opportunity to escape. Hence, the element of a deliberate
and premeditated attack necessary to establish treachery was absent. Abuse of
superior strength, though initially considered, was similarly not proven to the
court's satisfaction.
The Court sentenced the appellants to an indeterminate
sentence of eight years and one day of prision mayor as minimum, to fourteen
years, eight months, and one day of reclusion temporal as maximum.
Dispositive Portion:
"Aries H. Reyes and Demetrio M. Sahagun are found
guilty of homicide and sentenced to an indeterminate sentence of eight years
and one day of prision mayor as minimum to fourteen years, eight months, and
one day of reclusion temporal as maximum. They are further ordered to jointly
and severally pay the heirs of Jun Balmores P50,000.00 as civil indemnity;
P50,000.00 as moral damages; P28,266.15 as actual damages for medical, funeral,
and burial expenses; and P300,000.00 as temperate damages in lieu of actual
damages for loss of earning capacity. These amounts shall earn a six percent
interest per annum from finality of this decision until fully paid."
Should all conspirators be equally liable for a crime when
only one of them delivers the fatal blow?
Important Doctrines:
- Conspiracy
– When conspirators act in concert toward a common purpose, the act of one
is the act of all, even if not everyone physically participates in the
final blow.
- Treachery
– Treachery is absent when the attack is spontaneous and the victim has an
opportunity to defend himself or flee. It requires deliberate planning by
the assailant to ensure the victim cannot retaliate.
- Abuse
of Superior Strength – This requires proof that the assailants
consciously sought the advantage of their greater numbers or strength.
Mere numerical superiority does not automatically constitute abuse of
superior strength.
This case falls under Criminal Law.
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🎓 Welcome, future lawyers
and Bar examinees! In this episode, we’ll explore a significant jurisprudence
in Criminal Law—People of the Philippines v. Aries Reyes y Hilario and
Demetrio Sahagun y Manalili, G.R. No. 227013, promulgated on June
17, 2019.
This video will focus on helping law students and
baristas recall key doctrines tackled in this case. We'll walk you
through the legal issue, how the Supreme Court resolved it, and extract ten
crucial legal doctrines for your review and social media learning.
📚 NATURE OF THE CASE:
Criminal Law – Homicide (formerly charged as Murder)
TITLE: People of the Philippines vs. Aries Reyes y
Hilario and Demetrio Sahagun y Manalili
Promulgation Date: June 17, 2019
📌 CASE SUMMARY (IN
FOCUS):
A street altercation led to the death of a vendor, Jun
Balmores, after being chased, beaten, and stabbed by a group that included the
accused. While initially convicted of murder, the Supreme Court ruled
that treachery and abuse of superior strength were not sufficiently
proven, and thus the charge was reduced to homicide.
🧠 Should individuals be
held equally liable in a killing when they didn’t strike the fatal blow—but
were clearly part of the attack?
🎯 10 DOCTRINES FROM
THE CASE (With Factual Basis from Supreme Court Decision):
- Conspiracy
Doctrine
“In conspiracy, the act of one is the act of all.” All who participate with shared intent may be held equally liable, even if only one inflicts the fatal wound.
👉 [Decision, p. 33] - Treachery
Must Be Deliberate
Treachery is absent if the attack was spontaneous and the victim could escape or defend himself.
👉 [Decision, pp. 40-41] - Abuse
of Superior Strength Requires Deliberate Use
Mere numerical superiority does not establish abuse of superior strength unless the advantage was consciously used.
👉 [Decision, pp. 43-44] - Spontaneity
Cancels Treachery
A sudden fight that escalates into violence does not necessarily prove treachery.
👉 [Decision, p. 41] - Proof
Beyond Reasonable Doubt in Qualifying Circumstances
Qualifying circumstances like treachery must be proven with clarity to justify a murder conviction.
👉 [Decision, p. 38] - Conversion
from Murder to Homicide
If none of the circumstances under Article 248 RPC are proven, the crime is downgraded to homicide under Article 249.
👉 [Decision, p. 45] - Witness
Credibility is Crucial in Conspiracy
Credible, corroborated eyewitness accounts can establish concerted action among co-accused.
👉 [Decision, pp. 31-33] - Civil
Liability Despite Reclassification
Despite downgrading to homicide, the accused must still pay civil, moral, and temperate damages.
👉 [Decision, pp. 46-47] - Loss
of Earning Capacity Must Be Supported
Damages for lost earnings must be supported by documents or else only temperate damages are awarded.
👉 [Decision, p. 47] - Indeterminate
Sentence Law Applies in Homicide
In homicide, the court imposes a minimum and maximum term under the Indeterminate Sentence Law.
👉 [Decision, p. 45]
⚠️ DISCLAIMER:
This video is for educational purposes only and is not
guaranteed to be infallible. Made using premium AI tools with
references from official Supreme Court sources.
🙋 FREQUENTLY ASKED
QUESTIONS (FAQs)
- Q:
What was the original crime charged?
A: The accused were originally charged with murder. - Q:
Why did the Supreme Court downgrade the charge to homicide?
A: Because treachery and abuse of superior strength were not proven beyond reasonable doubt. - Q:
What was the final sentence?
A: 8 years and 1 day of prision mayor to 14 years, 8 months, and 1 day of reclusion temporal. - Q:
Was there compensation to the victim's family?
A: Yes. Civil indemnity, moral damages, actual and temperate damages totaling over ₱428,000 were awarded. - Q:
Is it necessary for all conspirators to inflict physical harm to be
liable?
A: No. Participation with shared criminal intent is enough to establish liability.
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🎓 Welcome, future
lawyers! This quizzer is based on a landmark Supreme Court case:
People of the Philippines v. Aries Reyes y Hilario and
Demetrio Sahagun y Manalili,
G.R. No. 227013, promulgated on June 17, 2019.
📚 Nature of the Case:
Criminal Law
In this case, the accused were charged with murder
after the death of a street vendor in Quiapo. The central issue: Can
individuals be held equally liable for a killing when they didn’t deliver the
fatal blow but actively participated in the assault?
The Regional Trial Court and the Court of Appeals
both convicted them of murder. However, the Supreme Court downgraded
the conviction to homicide, ruling that treachery and abuse of
superior strength were not sufficiently proven, though conspiracy
was established.
🎯 Use this quiz to
reinforce your understanding of Criminal Law doctrines on conspiracy,
qualifying circumstances, and liability.
📌 The answer key will
be provided at the end of the video.
🧠 10 HOTS (Higher Order
Thinking Skills) MULTIPLE CHOICE QUESTIONS (Easy Difficulty):
- What
was the final conviction of the Supreme Court in the case involving Aries
Reyes and Demetrio Sahagun?
- A.
Murder
- B.
Homicide
- C.
Parricide
- D.
Physical Injuries
- Why
did the Supreme Court reject the murder conviction originally imposed by
the trial courts?
- A.
Because the victim was a family member
- B.
Because treachery was not proven
- C.
Because the accused were minors
- D.
Because the weapon used was not lethal
- What
doctrine holds that when several individuals act with a common intent,
the act of one is considered the act of all?
- A.
Self-defense
- B.
Mistake of fact
- C.
Conspiracy
- D.
Double jeopardy
- What
was the primary reason for the Court's finding that treachery was absent
in this case?
- A.
The attack was committed during nighttime
- B.
The victim initiated the confrontation
- C.
The attack was spontaneous and unplanned
- D.
The victim was unaware of the threat
- Which
of the following best describes the participation of the accused in the
crime?
- A.
They were bystanders only
- B.
They assisted after the crime
- C.
They actively pursued and attacked the victim
- D.
They merely witnessed the act
- What
mitigating or qualifying circumstance did the lower courts incorrectly
apply according to the Supreme Court?
- A.
Premeditation
- B.
Treachery
- C.
Provocation
- D.
Self-defense
- Which
of the following statements is true regarding the liability of
co-conspirators?
- A.
They are only liable if they inflict the fatal blow
- B.
They are liable only if armed
- C.
They are equally liable regardless of who dealt the fatal injury
- D.
They are liable only for assisting after the crime
- What
penalty did the Supreme Court impose on the accused after modifying the
crime?
- A.
Life imprisonment
- B.
Death penalty
- C.
Indeterminate sentence of prision correccional
- D.
Indeterminate sentence from prision mayor to reclusion temporal
- What
kind of damages did the Supreme Court award to the victim’s family?
- A.
Nominal damages only
- B.
Civil, moral, and temperate damages
- C.
Punitive damages
- D.
Exemplary and legal interest only
- Which
element is not required to establish criminal conspiracy?
- A.
Prior agreement in writing
- B.
Unity of purpose among the accused
- C.
Concerted action at the time of the crime
- D.
Common criminal intent
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