G.R. No. L-31042-31043 - People vs. Canial y Alimon

On the evening of April 29, 1969, at about 9 o’clock, a shooting incident occurred on Elias Street, Sta. Cruz, Manila.
The incident resulted in the deaths of three persons: Benjamin (Totoy) Galang, Irineo (Erning) Navasca, and Zosimo Felarca.
Three separate informations for murder were filed on May 27, 1969, charging accused Marlo Canial y Alimon, Alfredo Edwards y Contreras, Janet Clemente y Hernandez, and Francisco Sevilla, alleging that they conspired to commit the crime with evident premeditation, treachery, and the use of a motor vehicle.

Reported that a white Toyota with five passengers (including the accused and Clarita Divina) stopped in front of Dolores Hernandez’ residence where a party was held.
Described the group’s movement—including entering and later exiting the house—and subsequent observations of Janet Clemente’s remarks and alleged gestures that pointed to the houses of several residents.
Noted how Canial was seen retrieving a paper bag from the car which contained a long firearm, and later, after his wife’s urging to leave, he heard gunfire and witnessed the ensuing violence.

Recounted that he saw the group in the white car near a “bahay kubo” and observed their exit onto the street followed by the approach of armed men.
Detailed how movements around the car led to gunshots and the positions in which the victims and accused were found.

Romeo Dalusong described his experience of hearing remarks from Janet Clemente and witnessing the scramble and gunfire that unfolded, including his own efforts to evade being shot.
Eduardo Meneses observed the arrival of Totoy Galang and Erning Navasca and testified to the presence of approaching gunshots and the chaotic attempt by bystanders to take cover.

Provided details on the arrangement of the accused within the car and the moment when armed men (identified as Totoy Galang and Erning Navasca) approached; one of whom issued a threat directed toward the occupants.
Described the ensuing physical struggle whereby Canial was forcibly removed from the vehicle and the subsequent scattering of events leading to chaos.

Other witnesses, including Rogelio Bonifacio, Florencio San Miguel (alias “Junior Ipis”), and Jesus Valdez, contributed accounts that provided insight into the interpersonal motives, prior conflicts, and behavior of the parties involved.
Forensic evidence was presented indicating the absence of powder burns on the hands of the victims and on the bullet holes in Galang’s garment, suggesting the shots were fired from a distance of at least one yard.
The defense, particularly through the testimony of Alfredo Edwards and Marlo Canial, alleged that they were at a birthday party and later in a situation of self-defense when forced to confront the armed group.

The trial court initially imposed three death penalties on Marlo Canial, Alfredo Edwards, and Janet Clemente, along with an order to indemnify the families of the deceased victims with both compensatory and moral damages as well as the payment of costs.
Accused Francisco Sevilla was acquitted for lack of sufficient evidence.
Appeals were filed against the decision, notably by Canial and Edwards, who admitted to the killings but pleaded self-defense.

Whether the shooting was premeditated or merely a spontaneous reaction to a sudden confrontation.

The central question revolved around the existence or absence of "evident premeditation" in the commission of the crimes.
Whether the actions of the accused—particularly in retrieving unlicensed firearms and positioning themselves in the car—indicated a deliberate plan to kill.

The validity of the self-defense claim raised by accused Canial and Edwards.

Whether the evidence sufficiently established the integrating elements of self-defense (illegal aggression, reasonable necessity, and lack of provocation).
Whether the physical evidence (absence of powder burns on the victims and the firing distances) rebutted their self-defense argument.

The extent of Janet Clemente’s liability based on her statements during the incident.

Whether her alleged remarks constituted a direct incitement or inducement compelling the killing actions of her co-accused.
Whether her participation in the events was sufficient to establish criminal liability or if she remained an accessory with no active role.