Title
People vs. Abubu y Valdez
Case
G.R. No. 129072
Decision Date
Jan 19, 2000
The Supreme Court overturns Antonio Abubu's murder and frustrated murder convictions, finding that the evidence indicates separate acts of shooting by multiple assailants.
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Case Digest (G.R. No. 129072)

Facts:

  • Antonio Abubu y Valdez, also known as "Boy Valdez," was charged with murder and multiple counts of frustrated murder alongside accomplices Jesus Valdez y Bueno, Oscar Dimarucut, Renato Manabat, and Rey Manabat.
  • The charges arose from an attack on February 18, 1996, at the home of Julius Golocan in Barangay Pinoma, Cauayan.
  • Flordeliza Golocan was preparing food when she saw Abubu and his accomplices at their front door.
  • Julius Golocan, holding their one-year-old son John Paul, opened the door to speak with them, while Flordeliza, with their three-month-old daughter Noemi, joined him.
  • The group opened fire without warning, resulting in Julius's death and serious injuries to Flordeliza and the children.
  • Police found Julius dead and the others critically injured, with evidence including two empty shells from a .357 revolver.
  • Flordeliza identified Abubu and Jesus Valdez as the attackers; both were apprehended shortly after, while the other accomplices escaped.
  • The trial revealed Julius had sustained five gunshot wounds, leading to his death, while Flordeliza and the children suffered life-threatening injuries.
  • The Regional Trial Court acquitted Jesus Valdez due to insufficient evidence but convicted Antonio Abubu of murder and multiple counts of frustrated murder, sentencing him to death and ordering damages to the victims' family.
  • The case was reviewed by the Supreme Court.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court determined that the trial court erred in convicting Antonio Abubu of the complex crime of murder with multiple frustrated murder, instead convicting him of separate crimes: one count of murder and three counts of frustrated murder.
  • The Supreme Court modified the sentence to reclusion perpetua...(Unlock)

Ratio:

  • The Supreme Court upheld the trial court's finding of guilt based on Flordeliza Golocan's positive identification of Antonio Abubu, emphasizing that the credibility of a single witness can suffice for conviction if convincing.
  • The Court noted Abubu's post-incident actions, such as fleeing to a cousin's house instead of reporting the crime, contradicted his claims of innocence.
  • The Court clarified that the nature of the crime did not cons...continue reading

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