Facts:

The case involves the appeal of Joemarie Chua y Baldevino, Joel Basco y Baldevino, Joefrey Basco y Parra, and Agosto O. Brosas, who were found guilty of two counts of murder and two counts of frustrated murder by the Regional Trial Court, Branch 38, Iloilo City, on January 8, 1996. The incidents occurred on January 20, 1994, in Barangay Cabanbanan, Municipality of Oton, Iloilo, Philippines. The accused were charged with the crimes after they allegedly conspired to kill several individuals during a shooting incident that resulted in the deaths of Charlie Sinoy and Arsenio Gajeto, as well as injuries to Erlindo Mana-ay and Perpetua Grace Gajeto. The prosecution's case was supported by testimonies from witnesses who identified the accused as the shooters. The defense, however, claimed that the shooting was accidental and that the accused were merely trying to retrieve a stolen motorcycle. The trial court conducted a joint trial for the four cases, leading to the conviction o...

Facts:

Incident Overview

• On January 20, 1994, at around 10:00 PM, in Barangay Cabanbanan, Oton, Iloilo, a group of individuals, including Charlie Sinoy, Arsenio Gajeto, Erlindo Mana-ay, and Nathaniel Presno, were having drinks near a sari-sari store. A jeepney owned by Joemarie Chua and driven by Agosto Brosas arrived, carrying Joel Basco and Joefrey Basco. A burst of gunfire ensued, resulting in the deaths of Charlie Sinoy and Arsenio Gajeto, and serious injuries to Erlindo Mana-ay and Perpetua Grace Gajeto.

Prosecution’s Case

• Five prosecution witnesses testified:
  1. Erlindo Mana-ay: Identified Joemarie Chua, Joel Basco, and Joefrey Basco as the armed individuals who fired at the group.
  2. Nathaniel Presno: Corroborated Mana-ay’s testimony, stating that the assailants were armed and fired at the victims.
  3. Jesus Cebu: Confirmed the presence of the accused and their involvement in the shooting.
  4. Corazon Gajeto: Testified about the injuries sustained by her husband, Arsenio Gajeto, and the events leading to his death.
  5. Perpetua Grace Gajeto: Described her injuries and identified the accused as the perpetrators.

Medical Evidence

• Erlindo Mana-ay: Suffered multiple gunshot wounds, with two pellets recovered from his body. Dr. Dennis Superficial testified that timely medical intervention prevented his death.
• Perpetua Grace Gajeto: Sustained gunshot wounds to her right foot and leg. Dr. Marcelo Jaen testified that without medical attention, she would have died.
• Charlie Sinoy: Postmortem examination revealed pellet wounds on his thighs, with one wound penetrating the femoral artery, causing his death.
• Arsenio Gajeto: Died from a gunshot wound to the right scapular area.

Defense’s Case

• The defense argued that only one shotgun was used, based on the recovery of two spent bullets and one dud ammunition. They also questioned the identification of the accused and the existence of conspiracy.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Positive Identification: The testimonies of the prosecution witnesses were credible and consistent, establishing the guilt of the accused-appellants beyond reasonable doubt.

2. Conspiracy: The concerted actions of the accused-appellants, including their simultaneous firing at the victims and fleeing together, demonstrated a common criminal design.

3. Treachery: The sudden and unexpected attack on the unarmed victims, who were relaxing and unable to defend themselves, qualified the crimes as murder with treachery.

4. Mitigating Circumstances: The Court recognized the privileged mitigating circumstance of minority for Joefrey Basco, reducing his penalty. The voluntary surrender of Joemarie Chua and Joel Basco was also considered as a mitigating factor.

5. Damages: The Court upheld the award of civil indemnity and moral damages but reduced the actual damages to reflect the evidence presented.