People vs.
De Jesus
G.R. No. L-58506 / Nov 19, 1982
Facts:
The defendants-appellants, Nilo de Jesus and Wilfredo Yalong, faced charges of murder for the death
of Feliciano de los Santos. The incident transpired on May 21, 1978, in Quezon City, following an
altercation between the deceased and the appellants. After the altercation, Feliciano was shot twice
and was pronounced dead upon arrival at the hospital. Post-incident, both appellants fled but were
later apprehended by authorities. During their arraignment, both pleaded not guilty to the charges.
Nilo de Jesus denied any involvement in the shooting, asserting that Yalong was the one who shot
Feliciano. Conversely, Wilfredo Yalong admitted to shooting Feliciano but claimed it was in self-
defense, asserting that the deceased, who was intoxicated, had attacked him with a bayonet. The
prosecution's case relied heavily on the testimony of Fernando de los Santos, the son of the deceased,
who alleged that De Jesus fired the fatal shot after seizing the gun from Yalong. However, this account
was contradicted by an unbiased witness, Anita Bernales, who testified that Fernando was not present
at the scene during the shooting. The trial court ultimately found both appellants guilty of murder and
sentenced them to reclusion perpetua.
Issue:
Was Fernando De los Santos's testimony credible enough to support the murder conviction?
Did evidence substantiate Wilfredo Yalong's self-defense claim?
Was there sufficient evidence to prove conspiracy between Nilo de Jesus and Wilfredo
Yalong?
Should the qualifying circumstance of treachery apply in this case?
Ruling:
The Supreme Court found Fernando de los Santos's testimony not credible, leading to Nilo de
Jesus's acquittal.
Wilfredo Yalong's claim of incomplete self-defense was acknowledged, modifying his charge
from murder to homicide.
The Court concluded there was no conspiracy between the appellants.
The qualifying circumstance of treachery was not applicable in this case.
The Court's decision centered on the credibility of the prosecution's lone witness, Fernando de los
Santos. The Court identified significant inconsistencies and contradictions in Fernando's
testimony, which undermined his account of the events. In contrast, the testimonies of the
appellants and the unbiased witness supported Yalong's assertion of self-defense, as he acted in
response to unlawful aggression from the deceased, who was armed with a bayonet. Although the
Court acknowledged that Yalong's actions were not entirely justified, they fell under the category
of incomplete self-defense, given that the means he employed were not deemed reasonable under
the circumstances. Furthermore, the Court dismissed the existence of conspiracy, emphasizing
that the presence of both appellants at the scene was coincidental and that Yalong acted alone in
shooting Feliciano. The absence of a premeditated agreement to commit the crime negated the
charge of conspiracy. Lastly, the Court rejected the finding of treachery, noting that the shooting
was a spontaneous reaction to an immediate threat, thus classifying the crime as homicide rather
than murder. Consequently, Yalong received a lesser penalty, while De Jesus was acquitted.
