Motive sometimes plays an important role in determining whether or not the accused is guilty of the crime charged. If the accused has no motive at all in committing a crime, he may be acquitted. But how is lack of motive convincingly proven as true and credible? Is proof of motive really vital and necessary for the conviction of an accused? If the accused has no motive can he still be found guilty? These are among the questions answered in this case of Leonard.
Leonard is one of the farmers in a hacienda located down south. Another farmer in the hacienda and a neighbor of Leonard, is Tony, married to Maita. Tony and Maita have one daughter Jecel who is quite mentally retarded. They also have a houseboy Gio, 15 years old, and a housemaid Libay also 15 years old. Also staying with them is Tony’s old and already blind aunt, Tiya Racquel.
The incident happened one afternoon at about four o’clock and was actually witnessed by Gio and Libay. Gio was then seated near the doorway of Tony’s house when Leonard arrived, carrying a black club about 25-1/2 inches long. Leonard asked Gio where his Pareng Tony was. Gio answered that he was asleep inside the room. So Leonard went inside and struck Tony with the club. The startled Gio can only asked him “what is that Nong”? Leonard retorted, “Are you going to defend him? I will also kill you.” So Gio ran down to a camote field, taking along with him Libay, Tiya Racquel and Jecel.
Libay also witnessed what happened as she was then cooking in the house when Leonard appeared and asked for his ‘Pareng Tony.” She saw Leonard entered the room and clubbed Tony with a piece of wood locally called “bahi” because the wall of Tony’s bedroom was made of spilt wood laths and there were gaps between the strips. As she went to the door she heard Leonard threatened to club Gio also. So she grabbed Jecel who was then asleep in the sala and together with Gio and Tiya Racquel, they ran and hid in the camote field. Later, they looked for a house where they could take shelter. Then they saw a lighted house, went inside and were admitted by a woman. They only learned that the house was owned by Leonard when the latter came in the evening. Thus Leonard shouted at them and threatened to kill them if they report to anybody what she and Gio saw. So they were “persuaded” by Leonard to stay in the house where they had the nine-day prayers for the dead upon learning that Tony already died.
Tony was found dead by Gio who returned to their house the following morning. Blood was coming out of the right side of the forehead. He also saw that a tree had fallen on the house. So he returned to the house of Leonard and asked him and other neighbors for help to get Tony’s body and bury him in the cemetery. After the burial they remained in Leonard’s house for the customary nine-day novena. Then Maita arrived and they transferred to the house of Tony’s mother, Linda in another town.
Three months later and after proper investigation by the police, Leonard was charged with the crime of murder for killing Tony. He was only arrested after two years following the issuance of the warrant.
At the trial, the prosecution presented Gio and Libay as the principal witnesses together with the NBI medico-legal officer who testified that Tony died because of fractures in different parts of the body caused by the physical blow of a blunt instrument like a piece of hardwood. But he also admitted on cross examination that the injuries could have also been caused by a falling beam of the house.
For his defense, Leonard declared that he never left his house that day and that Tony was killed when a tree fell on his house and crushed him due to a typhoon. And when Gio, Libay, Jecel and Tiya Racquel came and asked that they be allowed to stay in his house, he acceded. His story was corroborated by two other farmers working in the same hacienda and its overseer who admitted that they were Leonard’s friends. He also said that he had no motive at all to kill Tony.
The trial court however found Leonard guilty of murder as charged and sentenced him to suffer life imprisonment. The court gave more credence to the testimonies of the prosecution witnesses than on the version of Leonard. The court also said that his flight and evasion of arrest for two years are evidence of his guilt.
The Supreme Court affirmed the trial court’s decision on automatic review. It found that the testimonies of the prosecution witnesses are more credible despite inconsistencies because said discrepancies are on minor details that do not detract at all from their credibility. While no motive was shown why Leonard would want to kill Tony, such motive assumes pertinence only when there is doubt as to the identity of the culprit. It is not essential for conviction where the perpetrator of the offense is known or has been identified. In this case, Gio and Libay positively identified Leonard as the one who delivered blows on Tony while the latter was sleeping. These blows were confirmed by the findings of the medico-legal officer. So Leonard is really guilty as charged and his sentence is proper except the indemnity which should be raised to P12,000 (People vs Sales, G.R. 29340, April 27, 1972).
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