G.R. No. L-34089 - People vs. Candado y Sarte

Case Digest (G.R. No. L-34089)
Expanded Legal Reasoning

Facts:

Overview of the Case

The case involves the killing of Mario San Juan on September 1, 1970.
The accused—Gaudencio Candado y Sarte, Reynaldo Sadie y Malana, and Manuel Maglalang y Malda—were charged with murder, having allegedly conspired and mutually assisted in the commission of the crime.
The prosecution’s account alleges that the accused attacked the victim with bolos and knives, inflicting multiple stab and hacking wounds.

Details of the Crime

It is alleged that the accused acted with deliberate intent, treachery, and evident premeditation.
The victim, Mario San Juan, sustained eighteen stab wounds and twelve hacking wounds.
Medical evidence from a post-mortem examination performed by Senior Medico-Legal Officer Dario Nalagan revealed:

The stab wounds, eight of which were perforating and lethal due to hemorrhage.
The hacking wounds were mostly concentrated on the head, noticed as indications of a coordinated attack by at least two assailants.

Physical evidence also included a diagram (Exhibits “A-1” to “A-2”) and a necropsy report (Exhibit “A”) identified and signed by Nalagan and corroborated by signatures of Dr. Brion and Dr. Sunico.

Witness Testimonies and Evidentiary Submissions

For the Prosecution

Dario Nalagan testified regarding the nature, number, and distribution of the wounds, confirming the use of at least two types of sharp-edged instruments.
Police personnel (Rafael Atizado and Reynaldo Leyva) testified that they received information about the victim’s incident and identified the accused based on observations and the victim’s circumstances.
Alberto Fernandez, a key eyewitness, narrated the sequence of events on the night of September 1, 1970, providing details on how the group of accused surrounded and attacked Mario San Juan.
Additional evidences included corroborative details such as the victim’s inability to defend himself during a sudden and unanticipated assault.

For the Defense

The accused put forth an alibi in which they claimed to have been elsewhere at the time of the crime.
Defense witnesses, including Jaime San Pedro, Leon Santos Jr., Jose Paredes, Manuel Sararana, and others, testified to support the alibi of various accused:

Gaudencio Candado testified that he was driving along the Libertad, Pasay City-Bangkal, Makati route during the incident.

ii. Reynaldo Sadie testified that he was occupied in the Pasay City market and later provided detailed accounts of his whereabouts. iii. Manuel Maglalang asserted that he was in Arayat, Pampanga, at the time, supported by testimonies from Manuel Guese and others.

Some defense witnesses had apparent interests due to close relationships with the accused, which brought their credibility into question.

Other Pertinent Facts

The incident occurred in a crowded urban setting on Aurora Street, Pasay City, with the victim’s group originally en route to a bakery.
Observations by multiple eyewitnesses described the assailants as armed, with evidence suggesting that the attack was both deliberate and unexpected.
There was also evidence of conspiracy among the accused, given that the manner of the attack and the use of varied weapons indicated a coordinated plan.

Issues:

Credibility of Competing Testimonies

Whether Alberto Fernandez’s testimony, as the primary eyewitness who provided a detailed account of the incident, was credible and should outweigh the defense’s alibi claims.
The sufficiency and reliability of circumstantial evidence in establishing the presence and participation of the accused at the scene.

Validity of the Defense Alibi

Whether the alibi defenses offered by the accused were supported by positive, clear, and satisfactory evidence.
If the alibi defenses, supported by testimonies of friends and relatives with vested interests, could negate the identification of the accused at the scene of the crime.

Establishment of Conspiracy

Whether the evidence sufficiently established that there was an agreement or concert among the accused to commit the crime.
If circumstantial evidence can substitute for direct proof in proving that the accused acted in concert with a common purpose.

Presence of Treachery and Alevosia in the Commission of the Crime

Whether the manner of the attack, characterized by its suddenness and the victim’s inability to defend himself, amounted to treachery and a qualifying circumstance of murder.

Ruling:

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Ratio:

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Doctrine:

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Case Digest (G.R. No. L-34089) Core Legal Reasoning Expanded

Facts:

Case Digest (G.R. No. L-34089) Expanded Legal Reasoning

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Doctrine:

Case Digest (G.R. No. L-34089)
Core Legal Reasoning

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Case Digest (G.R. No. L-34089)
Expanded Legal Reasoning