G.R. No. 191060 - People vs. Alvarez

The case involves the People of the Philippines as the plaintiff-appellee and several accused, notably Edgar Allen Alvarez and Rodel Caballero, with others remaining at large.
The fatal incident concerned the murder of Nicanor Morfe Agon, who was fatally shot.
The accused were alleged to be members of a group (referred to as a Black Shark group) which conspired and collaborated in planning and executing the killing.

During arraignment, appellants Alvarez and Caballero entered pleas of not guilty.
The Regional Trial Court (RTC) of Batangas City, Branch 2, rendered a decision on May 11, 2007, finding the accused guilty beyond reasonable doubt of murder with the qualifying and/or aggravating circumstances of treachery and evident premeditation.
The RTC imposed the penalty of reclusion perpetua on Alvarez and Caballero and ordered payment of P100,000.00 as civil liability to the heirs of the victim.
Charges against other accused, who were still at large, were archived pending their apprehension.

Testimony by George Vitan, a self-confessed gunman, and other former members of the group (Arnel Balocon and Romulo Gasta) was central in establishing that the appellants were involved in the planning and execution of the murder.
Additional testimonies included:

PO2 Arnold Abdon of the police, who confirmed that the victim was already dead when he arrived at the hospital.
Medico-Legal Officer Dr. Antonio S. Vertido’s post-mortem examination, which revealed that Agon sustained six gunshot wounds, with two being fatal.

The evidence established the necessary elements that a person was killed, that the accused were responsible, and that the killing was attended by qualifying circumstances.

Testimonies indicated that the plan to murder Agon was conceived a day prior to the execution of the killing.
The accused and their cohorts planned to ambush Agon while he was caught unawares—traveling in his vehicle—ensuring he could not defend himself.
Evidence showed that the method of approach and execution was deliberate, consistent with the qualifying circumstance of treachery.
There was clear unity of action among the members of the Black Shark group, and evidence of conspiracy was established by their prior agreement to commit the felony.

Appellants argued that the evidence presented was insufficient to prove their guilt, pointing out several alleged deficiencies:

The prosecution’s witnesses did not testify on key material allegations stated in the complaint and their sworn statements.
There was no proof that the victim was indeed the person identified in the death certificate.
The murder weapons and related physical evidence (slugs) were not presented in court.
No testimony was rendered regarding the caliber of the gun used.
The discontinuance of the presentation of additional witnesses was alleged to have denied them a proper opportunity to present their case.

The trial court, however, determined that these issues did not affect the sufficiency of the evidence to establish all the elements of the crime of murder.

Whether the evidence presented by the prosecution was sufficient to establish beyond reasonable doubt that Agon was killed by the accused.
Whether the elements of murder—notably, the killing with treachery and evident premeditation—were adequately proven.

Whether appellants were denied due process based on the alleged non-testimony on material points in their sworn statements.
Whether the prohibition against presenting additional witnesses, as ordered by the RTC, violated the right to a fair trial.

Whether the evidence was adequate to constitute conspiracy among the accused to commit the murder.
Whether the collective action of the group imputed the criminal liability equally to all conspirators, regardless of the specific role of each.

Whether the imposition of reclusion perpetua, in lieu of the death penalty, was appropriate given the aggravating circumstances.
Whether the additional imposition of civil indemnity, moral, exemplary, and temperate damages was properly calculated and justified.