Case Digest (G.R. No. 84423)
Facts:
Jose Navarro y Borlongan v. The Honorable Court of Appeals, and The People of the Philippines, G.R. No. 84423, January 31, 1989, Supreme Court Second Division, Sarmiento, J., writing for the Court.The petitioner, Jose Navarro y Borlongan, was charged in an information dated August 6, 1984 with murder (later treated as homicide by the trial court) together with Nestor Quezon y Villegas and a John Doe, Alias Talao, for the fatal shooting on December 29, 1983 of Patrolman Leonardo Enriquez in Limay, Bataan. At arraignment on August 14, 1984 Navarro and Quezon pleaded not guilty; the John Doe remained at large. The information alleged evident premeditation and treachery, and narrated that the assailants shot the victim with a firearm.
The Regional Trial Court of Balanga, Bataan, Branch IV found Navarro guilty on February 26, 1987 as an accomplice in the crime (appreciating mitigating circumstances) and sentenced him to an indeterminate term of prision correccional to prision mayor, ordered indemnities and damages, and acquitted Quezon for lack of proof. Navarro appealed to the Court of Appeals assigning as error that his conviction rested on unstable, conflicting and uncorroborated circumstantial evidence drawn essentially from a single witness, Patrolman Florante Mendoza, who was a friend and co-worker of the victim.
The Court of Appeals, in a decision reported July 28, 1988, affirmed the conviction but modified Navarro’s criminal liability to that of a co-principal, imposed a heavier indeterminate penalty, and increased the award of indemnity for the victim’s death. The prosecution’s case at trial relied heavily on Mendoza’s testimony recounting an earlier quarrel between Navarro and Enriquez at a beach gathering, Navarro’s leaving and returning with Quezon and a man called Talao, Mendoza’s description of Talao firing the shots from behind the victim, Mendoza’s being threatened and disarmed, and Navarro’s alleged admonition not to report the incident.
Navarro filed a petiti...(Subscriber-Only)
Issues:
- Did the sole testimony of Patrolman Florante Mendoza satisfy the requisites of circumstantial evidence to sustain a conviction beyond reasonable doubt?
- Was there sufficient proof of conspiracy to convict Jose Navarro as a co-principal or conspirator in the killing of Patrolma...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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