Facts:

The case involves Antonio Abubu y Valdez, alias "Boy Valdez," who, along with his accomplices Jesus Valdez y Bueno, Oscar Dimarucut, Renato Manabat, and Rey Manabat, was charged with murder and multiple counts of frustrated murder in the Regional Trial Court of Cauayan, Isabela. The charges stemmed from an incident on February 18, 1996, when Julius Golocan and his family were attacked at their home in Barangay Pinoma, Cauayan. At approximately 5:30 PM, Flordeliza Golocan was preparing food when she noticed Abubu and his companions at their front door. Julius, carrying their one-year-old son John Paul, opened the door and stepped outside to speak with them. Flordeliza, holding their three-month-old daughter Noemi, joined them. Without warning, the group opened fire, resulting in Julius's death and serious injuries to Flordeliza and their two children.

The police responded to the scene, where they found Julius dead and the others critically injured. Evidence co...

Facts:

• Incident Overview: On February 18, 1996, at around 5:30 PM, Julius Golocan, his wife Flordeliza, and their two children, John Paul and Noemi, were attacked at their home in Barangay Pinoma, Cauayan, Isabela. Julius was killed, while Flordeliza and the children sustained critical injuries.
• Perpetrators: The assailants were identified as Antonio Abubu alias "Boy Valdez," Jesus Valdez, Oscar Dimarucut, Renato Manabat, and Rey Manabat. Only Abubu and Jesus Valdez were apprehended; the others remained at large.
• Crime Scene Investigation: Police recovered two empty .357 revolver shells at the scene. The house’s walls were peppered with bullet holes. Julius was found dead, while Flordeliza and her children were rushed to the hospital.
• Victims’ Injuries:
  • Julius sustained five gunshot wounds, leading to massive hemorrhage and death.
  • Flordeliza was shot in the right upper arm, with the bullet lodging in her right lung.
  • John Paul suffered a gunshot wound to the head, while Noemi was shot in both feet.
• Defense Claims:
  • Abubu claimed he left the scene before the shooting occurred and was 100 meters away when he heard gunshots.
  • Jesus Valdez denied involvement, claiming he was drinking with others at the time.

Issue:

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Ruling:

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Ratio:

1. Complex Crime Not Applicable: The killings and injuries resulted from multiple distinct acts, not a single act, as required under Article 48 of the Revised Penal Code. Each victim was shot separately, and different guns were used.
2. Treachery Established: The attack was sudden and unexpected, leaving Julius and his family defenseless. The assailants consciously adopted a treacherous method of attack.
3. Credibility of Witness: Flordeliza’s positive identification of Abubu as one of the assailants was deemed credible. Her testimony, corroborated by evidence, was sufficient to establish his guilt beyond reasonable doubt.
4. Penalty Determination:
   • For murder, the absence of aggravating or mitigating circumstances mandates the lesser penalty of reclusion perpetua.
   • For frustrated murder, the penalty is one degree lower than reclusion perpetua, resulting in an indeterminate sentence under the Indeterminate Sentence Law.
5. Damages: The Court upheld the awards for indemnity, moral damages, funeral expenses, and medical expenses, ensuring adequate compensation for the victims and their heirs.