G.R. No. 93899 - People vs. Cadag y Cabotaje

Early on March 14, 1989, the cadaver of Arnel Claridad was discovered in the Far East High School compound, located at Poblacion East, Sta. Maria, Pangasinan.
Patrolman Conrado Balmores, upon arriving at the crime scene, observed a trail of blood leading from the schoolgate to the spot where the body was found.
Initial inquiries revealed that the victim was last seen the previous night with Lorna Taguiped, the common-law wife of the accused-appellant Eddie Cadag alias Simen.

On March 30, 1989, Lorna Taguiped executed her first sworn statement before the NBI, declaring that she, along with the appellant, was at home the entire evening of March 13, 1989, and denied any knowledge of the incident.
On July 10, 1989, after ending her relationship with the appellant, Lorna voluntarily executed another sworn statement before the police. In this later testimony, she implicated the appellant as the assailant of Arnel Claridad.
According to her account, at approximately 7:00 p.m. on March 13, 1989, the appellant, driven by jealousy over her previous relationship with Boyet Claridad, took her to the poblacion to fetch Boyet.
At the residence of Boyet, when Boyet’s brother Arnel informed her that Boyet was not present, Arnel decided to follow her along the way back.
Upon reaching the front of the Far East High School, the appellant emerged from the darkness, greeted by Arnel’s remark, “So, you are here. Why are you here, Simen?”
Without warning, the appellant attacked Arnel by stabbing him in rapid succession—first in the left waist, then on the right face, followed by another stab to the right waist below the breast.
Although Arnel managed to run a few meters to seek shelter beneath a banana tree within the school compound, the appellant pursued him and continued to stab him repeatedly until death ensued.
Even after leaving the body, the appellant returned briefly to inflict additional fatal wounds at the neck and breast.

Dr. Susan Casaclang, the Municipal Health Officer, examined the cadaver and issued a detailed medical certificate.
External findings included multiple lacerations and puncture wounds on the head, face, neck, chest, abdomen, and limbs. Specific injuries noted were:

Abrasions and lacerated wounds on the head and face (including the fronto-temporal area, lateral orbit, and cheek).
Puncture and lacerated wounds on the sternal area and subcostal regions, with some wounds traversing ribs and affecting vital organs such as the liver and lungs.
Broken ribs and laceration of the left lung’s upper lobe, along with fracture of the 8th and 9th ribs on both sides.

The appellant claimed that on the night of March 13, 1989, he was at home in San Mariano, Sta. Maria, Pangasinan, in the company of his common-law wife Lorna Taguiped and his mother, Teresita Cadag.
He asserted that he had no personal acquaintance with Boyet or Arnel Claridad and denied having sent Lorna to Boyet’s house.
Instead, he contended that their neighbor, Marcelo Pacion, was the object of his jealousy as he often visited Lorna when the appellant was away.
Multiple witnesses supported his alibi:

Teresita Cadag, his mother, confirmed that he was at home the entire evening of March 13, 1989.
Emilia Agbunag, a neighbor, testified that she observed the appellant with Lorna and Teresita between 8:00 and 9:00 p.m. at their home.

The trial court convicted Eddie Cadag alias Simen of the crime of murder, qualifying it by treachery.
The sentencing imposed reclusion perpetua, along with a directive to indemnify the legal heirs of Arnel Claridad with Thirty Thousand Pesos (P30,000.00) plus additional P16,590.00 as actual damages, and to pay the costs of the proceedings.
The definitive language in the dispositive portion of the decision clearly stated the court's findings and imposed the penalties accordingly.

On appeal, the appellant contested the credibility of Lorna Taguiped, highlighting the existence of two contradictory sworn statements and arguing that she had a motive to kill Arnel due to her complicated relationship with Boyet Claridad.
The appellant’s defense further relied on his alibi testimonies, which were primarily attested by himself, his mother, and a neighboring witness.
The appellate court found that despite the inconsistencies in Lorna’s earlier statements, her later testimony before the police—albeit made after her separation from the appellant—remained reliable.
Moreover, the physical evidence corroborated her account, and the motive attributed to her did not outweigh the evidence implicating the appellant.
The court also noted the inherent weaknesses in alibi defenses established by parties with personal interest, such as relatives, thereby deeming the alibi as dubious.

Whether the evidence, including Lorna Taguiped’s testimony (despite her initially contradictory sworn statements), is strong enough to establish beyond reasonable doubt that the appellant committed murder.
Whether the corroborating physical evidence from the crime scene, notably the autopsy and blood trail, conclusively linked the appellant to the crime.

Whether the appellant’s alibi—testified by himself, his mother, and a neighbor—is credible given the proximity of his residence to the crime scene and the potential bias inherent in self-serving accounts.
Whether the distance between San Mariano and the poblacion is sufficient to establish that the appellant could not have been present at the scene of the crime.

Whether the lack of a clear proof regarding motive from the appellant undermines the conviction, given the combination of eyewitness testimony and physical evidence.

Whether the legal principles elucidated in precedents such as People vs. Perante, Jr., People vs. Gapasin, and People vs. Pacada, Jr., support the trial court’s findings on issues like treachery and the validity of alibi defenses.