Case Digest (G.R. No. 97285)
Facts:
In the case of People of the Philippines vs. Nestor Alapan and Francisco Clavido, G.R. No. 97285, decided on June 16, 1995, the Regional Trial Court of Oroquieta City found Nestor Alapan and Francisco Clavido guilty of murder, sentencing them to reclusion perpetua and ordering them to indemnify the heirs of the victim, Renato Adecer, in the amount of P30,000.00. The incident occurred on February 4, 1990, in San Isidro, Sinacaban, Misamis Occidental, when Renato, a 20-year-old man courting Annelyn Poledo, was attacked by the accused along with Cresente Pija, who remains at large. Renato was walking home with four friends after escorting Annelyn when he was suddenly assaulted. The prosecution presented three eyewitnesses—Nilo Madronero, Rodrigo Macas, and Vicente Idol—who testified that Renato was hacked and stabbed to death by the accused. Madronero, a 13-year-old pupil, recounted how Pija attacked Renato with a bolo, followed by Alapan stabbing him with a knife while Clavid...
Case Digest (G.R. No. 97285)
Facts:
Incident Overview:
- Nestor Alapan and Francisco Clavido, along with Cresente Pija (who remains at large), were accused of murdering 20-year-old Renato Adecer.
- The incident occurred on February 4, 1990, in San Isidro, Sinacaban, Misamis Occidental.
- Renato Adecer was courting Annelyn Poledo, who was also being courted by Cresente Pija.
Prosecution’s Version:
- Renato Adecer and his four friends were walking home after escorting Annelyn Poledo.
- They were attacked near the market of San Isidro Alto.
- Cresente Pija hacked Renato on the forehead with a bolo.
- Nestor Alapan repeatedly stabbed Renato with a hunting knife while Francisco Clavido held the victim, preventing him from defending himself.
- Renato died from multiple stab and hacking wounds, as confirmed by Dr. Gloria Bongabong.
Eyewitness Testimonies:
- Nilo Madronero (13 years old):
- Saw Pija hack Renato on the forehead, followed by Alapan stabbing the victim while Clavido held him.
- Rodrigo Macas (16 years old):
- Corroborated Madronero’s account, adding that Pija also hacked Renato on the neck.
- Vicente Idol (21 years old):
- Provided additional details, stating that Alapan and Clavido were seated on the left side of the road while Pija was on the right.
- Renato greeted them, and Pija suddenly attacked him.
Defense’s Version:
- Alapan and Clavido claimed they were drinking Tanduay Rhum with Pija in the market earlier that day but separated before the incident.
- They presented witnesses who claimed Pija acted alone.
- Barangay Captain Mamerto Aganos testified that Pija surrendered the bolo and confessed to killing Renato over a woman.
Issue:
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Ruling:
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Ratio:
Credibility of Witnesses:
- The trial court’s assessment of witness credibility is given great weight, as it has the opportunity to observe their demeanor and conduct.
- The prosecution witnesses testified vividly and consistently, with no evidence of improper motive to falsely implicate the appellants.
Alibi Defense:
- Alibi is a weak defense, especially when the accused are positively identified by credible witnesses.
- Alapan and Clavido failed to prove they were far enough from the crime scene to be physically incapable of participating in the killing.
Human Behavior in Startling Situations:
- There is no standard behavioral response to a shocking or frightening event. The witnesses’ immobility during the attack does not render their testimonies incredible.
Participation in the Crime:
- The prosecution proved beyond reasonable doubt that Alapan and Clavido actively participated in the killing.
- Alapan repeatedly stabbed the victim, while Clavido held him, ensuring the crime’s success without risk of retaliation.
Scapegoating Pija:
- The defense’s attempt to pin the entire blame on Pija, who remains at large, is suspicious and unsupported by credible evidence.