G.R. No. L-1278 - Barrioquinto vs. Ferdez

On February 18, 1996, the Golocan family—Julius Golocan, his wife Flordeliza, and their two young children (one-year-old John Paul and three-month-old Noemi)—became victims of a shooting incident in Barangay Pinoma, Cauayan, Isabela.
The incident occurred around 5:30 in the afternoon when Flordeliza, preparing food, heard knockings at the door and saw accused-appellant Antonio Abubu accompanied by four companions.

Julius Golocan, carrying his infant son and later joined by Flordeliza with Noemi, opened the door to converse with the visitors.
The group, after engaging in conversation, suddenly drew their firearms and started shooting; the assault resulted in Julius being fatally shot while Flordeliza and the children sustained critical injuries.

Responding police officers, SPO2 Jim D. Gabrillo and SPO1 Rico G. Cagurangan, arrived at the scene to find Julius dead and the rest of the family seriously wounded, with the house’s walls riddled with bullet holes and empty shells recovered from a .357 revolver.
The victims were transported to various medical facilities: Flordeliza and the children were initially treated at the Cauayan District Hospital, later transferred to Dr. Ester R. Garcia Hospital and then to Baguio General Hospital for further care; meanwhile, Julius’s body was examined post-mortem at the Carbonel Funeral Parlor by Dr. Antonio O. Abogado.

Flordeliza S. Golocan identified Antonio Abubu as one of the assailants; her testimony was supported by details of their previous acquaintance, noting that he used to work in their ricefields and was even allowed to sleep at their house.
Accused-appellant Antonio Abubu was later apprehended at his cousin Jerry Capinding’s residence, whereas accused Jesus Valdez was arrested at the home of his brother-in-law; three other accused individuals (Oscar Dimarucut, Renato Manabat, and Rey Manabat) remain at large.

The charges included murder for the death of Julius Golocan and three counts of frustrated murder for the injuries sustained by Flordeliza, John Paul, and Noemi Golocan under four separate Informations.
At trial, while Jesus Valdez was acquitted for failure of proof beyond reasonable doubt, Antonio Abubu was convicted for murder complexed with multiple frustrated murders, with the trial court originally sentencing him to death and ordering payment of various compensatory, moral, and actual damages to the victims’ families.

Post-mortem findings on Julius indicated five gunshot wounds with uniform bullet diameters and marked evidence of the gunshot trajectory, supporting the occurrence of multiple distinct shootings.
Medical testimonies confirmed that despite the severe injuries sustained by Flordeliza and her children, immediate medical intervention was the key factor in their survival, while establishing the lethality of the wounds inflicted.

Whether the trial court erred in finding accused-appellant Antonio Abubu guilty beyond reasonable doubt based on the evidence presented, particularly relying on the testimony of Flordeliza S. Golocan.
Whether the accused’s actions following the incident, including his attempt to evade immediate contact with the authorities, sufficiently corroborated his guilt.

Whether the imposition of a death sentence for what was argued to be a complex crime of murder with multiple frustrated murder was legally and factually warranted.
Whether the separate nature of the acts committed (distinct shootings at different times and by different assailants) precludes a conviction for a complex crime and mandates separate penalties for murder and frustrated murder.