Case Digest (G.R. No. L-40392)
Facts:
The People of the Philippines v. Generoso Alegria, G.R. No. L-40392, August 18, 1978, Supreme Court Second Division, Aquino, J., writing for the Court. Generoso Alegria (accused-appellant) appealed the judgment of the Court of First Instance of Iloilo convicting him of murder, sentencing him to reclusion perpetua and ordering payment of P12,000 indemnity to the heirs of Bienvenido Alegria (Crim. Case No. 3121).
On the evening of March 10, 1972, Bienvenido Alegria was fatally shot in Sitio Guibuangan, Barrio Tigbauan, Cabatuan, Iloilo, sustaining multiple gunshot wounds and dying of hemorrhage and shock. Although local Constabulary and police were informed and inspected the scene, no immediate written complaint or formal statement was made; the victim’s widow, Teresa Aureal, and a neighbor, Teodorico Comprendio, executed sworn statements only on November 15, 1973 before Sergeant Josue Solinap and swore them before the municipal judge. An information for murder was filed by an assistant provincial fiscal on December 13, 1973.
At trial Teresa testified that between 5:30 and 6:30 p.m. she called her husband home; Generoso suddenly appeared, passed her, and shot Bienvenido with a homemade shotgun (pugakhang), after which Bienvenido fell in the rice paddy. Comprendio corroborated this account, describing Generoso running with a shotgun and firing when he saw Bienvenido. The barrio captain, Cesareo Lampareo, also testified to arriving at the scene after hearing a cry for help. The witnesses explained the delayed formal statement by fear and family circumstances.
Generoso denied the quarrel alleged to have preceded the killing and offered an alibi: he claimed to have cooked and slept at Maria Celendro’s house during the relevant evening because of a fiesta in the neighboring barrio; his alibi was supported by Maria Celendro and Rafael Vales. He also accused another relative, Crispin Aureal, as the possible gunman. At preliminary investigation Generoso protested the accusation and challenged the credibility of the prosecution witnesses, asserting prior enmity and suggesting witness fabrication. Police witnesses for the defense reported they could not identify the kil...(Pro-only)
Issues:
- Did the prosecution prove Generoso Alegria’s guilt beyond reasonable doubt?
- Was the killing properly characterized as murder qualified by treachery and was the penalty impos...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)