Case Digest (G.R. No. 127803)
Facts:
People of the Philippines v. Juanito Abella, Diosdado Granada, Benjamin De Guzman, and Edgardo Valencia, G.R. No. 127803, August 28, 2000, Supreme Court First Division, Davide Jr., J., writing for the Court.On 10 March 1992 the decomposing bodies of Marlon Ronquillo, Joseph Ronquillo, Erwin Lojero, Andres Lojero, Jr., and Felix Tamayo were recovered from the Pasig River; postmortem examinations showed ligature marks, contusions, skull fractures and other signs of foul play. Five informations for murder were filed on 18 March 1992 in the Regional Trial Court (RTC) of Manila against several persons, including Juanito Abella, Diosdado Granada, Benjamin De Guzman, and Edgardo Valencia; the informations alleged abduction, mauling, tying of hands, and throwing of the victims into the river. The informations were amended on 25 March 1992 to add three more accused; several later were dropped. The cases were raffled to Branch 52 (Judge David Nitafan). Upon arraignment the accused pleaded not guilty.
Prosecution witnesses described an altercation during a March 7 basketball game and subsequent incidents on March 8 in Bacood, Sta. Mesa: the De los Santos brothers allegedly pointed out the victims; a dirty white Ford Fiera then arrived with some passengers wearing handkerchiefs and armed; the victims were seized, beaten and loaded into the van; a witness, Elena Bernardo, followed and testified she saw the victims tortured in a basement at the Iglesia ni Cristo (INC) compound. Bodies were found three days later. Eyewitnesses identified appellants in police line-ups. The accused asserted alibi: attendance at INC “panata” rites (8–10 p.m.) and, as to Abella, police duty on Roxas Boulevard.
After prolonged trial, Judge Nitafan inhibited on 7 February 1995 and the cases were re-raffled to Branch 35 (Judge Ramon P. Makasiar). On 15 November 1996 the RTC, Branch 35, convicted the four appellants of five counts of murder, sentenced each to five reclusion perpetua, and ordered damages and indemnities (the decision later amended to include P50,000 indemnity per victim). The appellants elevated the case to the Supreme Court; they u...(Pro-only)
Issues:
- Was there positive and clear identification of the accused by eyewitnesses?
- Was the trial court justified in giving credence to the testimony of eyewitness Elena Bernardo despite discrepancies with physical evidence?
- Was the circumstantial evidence adduced by the prosecution sufficient to sustain conviction?
- Was the appellants’ defense of alibi sufficiently established to raise reasonable doubt?
- Was treachery present to qualify the killings as murder, and may abuse of superior strength be treated separately?
- Did the appellants’ visit to the police to clear their names ...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
- (Pro-only)