G.R. No. 191425 - Nollora, Jr. vs. People

An altercation began during a basketball game between members of two teams.
On March 7, 1992, during the basketball game, a brawl broke out after the Ronquillo team won the first two rounds against Joey de los Santos’ team, leading the latter to return with pillboxes.
On March 8, 1992, between 5:00 and 6:00 p.m., an incident occurred at the Ronquillosa house in Lakas Street where Joey and his brother Gener threw stones at the house.
Later that evening, between 8:00 and 9:00 p.m., a dirty white Ford Fiera, carrying approximately ten to thirteen individuals with faces covered by black handkerchiefs and armed, stopped near the group of victims.
Witnesses observed that Joey and Gener pointed at the victims who were then overpowered, dragged into the van, and herded into a basement of an Iglesia ni Cristo (INC) compound in Punta, Sta. Ana.
Inside the basement, the victims were brutally maimed, beaten with steel tubes, lead pipes, guns, and other blunt instruments.
The victims were later loaded back into the van which sped away, and three days after the altercation, on March 10, 1992, their bodies were retrieved from the Pasig River.

Marlon Ronquillo: Had his hands tied with a black electric cord, sustained lacerated wounds, contusions, ligature marks, hematoma, and died of a gunshot wound to the head.
Andres Lojero, Jr.: His hands were bound with a plastic flat rope; his genitals were cut off; evidenced ligature marks, contusions, and hematoma; cause of death was asphyxia by strangulation with intracranial hemorrhage.
Joseph Ronquillo: Bound using a basketball T-shirt; sustained lacerated wounds, contusions, ligature marks, fractures, and died from asphyxia by strangulation along with traumatic intracranial hemorrhage.
Erwin Lojero: Exhibited abrasions, burns, cord impressions on the wrists, depressed skull fracture; died from asphyxia by drowning with blunt head injury.
Felix Tamayo: Had abrasions and tie impressions on the left cheek; cause of death was asphyxia by drowning.

Postmortem examinations indicated signs of foul play, suggesting deliberate and violent acts against the victims.

On March 18, 1992, five informations for murder were filed before the Regional Trial Court of Manila against six accused individuals initially.
The informations charged the accused with conspiring to kill the victims with treachery and evident premeditation, describing in detail the methods of assault, abduction, and subsequent murder.
The allegations included acts such as tying the victims, physically assaulting them, and throwing their bodies into the river, with accompanying evidence such as witness testimonies and physical findings from the cadavers.
Subsequent amendments to the information on March 25, 1992, included additional accused and refined allegations.

The accused — Juanito Abella, Diosdado Granada, Benjamin De Guzman, and Edgardo Valencia — were identified by multiple witnesses as key participants during the abduction and subsequent abuse of the victims.
Testimonies indicated that:

Josephine identified Abella and Granada from the van.
Evelyn corroborated by identifying multiple appellants.
Witnesses such as Wilfredo Lojero, who was present during the abduction and a relative to some victims, provided crucial identification.

The accused also presented an alibi claiming attendance at the INC panata rites on March 8, 1992, with the exception of Abella, who was excused due to his duty as a member of the PNP.

The physical evidence, including the state of the victims' bodies (tied hands, injuries, signs of struggle) corroborated the violent nature of the crime.
A police line-up was hastily organized based on information provided by a former accused and other officials, during which all accused were identified by witnesses.
The trial court proceedings, initially overseen by Judge David Nitafan until his inhibition, were reassigned to Judge Ramon P. Makasiar who convicted the accused on five counts of murder and ordered severe penalties along with awards for actual, moral, and exemplary damages.
The decision was later amended to reduce the moral and exemplary damages from ₱500,000 to ₱50,000 each, while affirming most of the conviction's findings.

Whether the positive and clear identification of the accused by witnesses such as Josephine and Evelyn was sufficient, particularly when discrepancies existed between the sworn statements and courtroom testimonies.
The credibility and reliability of the eyewitness Elena Bernardo, whose testimony allegedly contained inconsistencies, notably regarding the method of killing (claiming stab wounds contrary to the physical evidence).

Whether the circumstantial evidence, which comprised the sequence of events from the basketball altercation, stoning incident, and later abduction, was sufficient to establish the guilt of the accused beyond reasonable doubt.
The connection or gap between the accused’s alleged presence at the scene and the physical evidence linking them to the abduction and murder of the victims.

Whether the defense of alibi, with the accused claiming attendance at the INC panata rites, was properly evaluated and whether it could have created a reasonable doubt as to their presence at the crime scene.
The evidentiary value of the alibi, given the possibility that members could leave unnoticed during the panata.

Whether treachery was appropriately considered to qualify the killings as murder, particularly given that the victims were bound and rendered defenseless.
If additional qualifying circumstances, such as superior force, needed to be independently proven or if treachery alone was sufficient under the circumstances.

Whether the voluntary surrender of the accused, purportedly in an attempt to clear their names, could be considered a mitigating circumstance.
The proper legal interpretation of “voluntary surrender” in the context of the accused’s actions and subsequent behavior.