Case Digest (G.R. No. 98425-26)
Facts:
The case is People of the Philippines v. Reynaldo Aguilar alias "Nonong", G.R. Nos. 98425-26, May 21, 1993, Supreme Court Third Division, Davide, Jr., J., writing for the Court. The plaintiff-appellee is People of the Philippines; the accused-appellant is Reynaldo Aguilar alias Nonong.On the evening of 1 August 1989 at Sitio Simsiman, Barangay Marguez, Municipality of Esperanza, Province of Sultan Kudarat, Marcelino Aquino was fatally struck by a gunshot while shelling corn with his mother Lilia Aquino; three additional gunshots followed and then a hand grenade exploded, injuring Ailleen (Aileen) Aquino and Argie Aquino. Based on the claim of Ailleen and her husband Salustiano Aquino that one perpetrator was Nonong Aguilar (then Station Commander of Esperanza), two criminal complaints were filed in August 1989: one for murder and one for multiple frustrated murder. Aguilar was arrested on 16 August 1989; bail proceedings were addressed at the 4th Municipal Circuit Trial Court, which ordered the cases transmitted to the Provincial Prosecutor.
On 25 September 1989 the Provincial Prosecutor filed Informations in Branch 19, Regional Trial Court (RTC), Isulan, Sultan Kudarat: Criminal Case No. 1856 (Murder, alleging multiple gunshots with treachery and premeditation, Article 248 RPC) and Criminal Case No. 1857 (Multiple Frustrated Murder by grenade, Article 248 in relation to Article 6 RPC). Aguilar pleaded not guilty at arraignment on 2 November 1989; the cases were consolidated for joint trial.
At trial the prosecution principally relied on testimony of Salustiano and Lilia Aquino in chief and Ailleen Aquino on rebuttal; documentary exhibits included medical certificates and a death certificate. The defense presented Crescencio Dolero, Dionisio Castor, Ricardo Aguilar, Pfc. Merly Sevilla and the accused (raising alibi). On 15 January 1991 the RTC convicted Aguilar of Murder (Crim. Case No. 1856) and Multiple Attempted Murder (Crim. Case No. 1857), imposed respective penalties, and awarded indemnity; the court gave credit for preventive detention under Article 29 RPC as amended.
Aguilar appealed to the Supreme Court (mode of review: appeal by certiorari from the RTC judgment as an ordinary appeal accepted under the Court’s resolution), raising e...(Pro-only)
Issues:
- Did the trial court err in crediting the prosecution eyewitnesses’ identification of appellant as perpetrator?
- Did the trial court err in failing to give due weight to the defense witnesses and appellant’s alibi?
- Was there proof beyond reasonable doubt that appellant either fired the fatal shot/threw the grenade or that he conspired with others so...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)