G.R. No. L-61408 - People vs. Clores

The incident involved the murder of Victorio Barcarse, Jr., whose disappearance led to the filing of a criminal case.
The crime occurred against the backdrop of a proposed marriage between Victorio and Salome, daughter of Isidro Clores, where discussions of the wedding arrangement had taken place.
Felisa Barcarse, accompanied by her son, visited Isidro Clores’ residence in Carinsan Sur, Tuguegarao, Cagayan to seek the hand of Salome for Victorio.

On April 11, 1970, Felisa Barcarse and Victorio visited the Clores home and were warmly received.
The discussion on the proposed wedding was paused, pending the arrival of appellant Edmundo Clores and an elder brother from Manila.
On April 24, 1970, Cynthia Clores, the 14-year-old daughter of Isidro, went to Felisa Barcarse’s house to fetch Victorio for further discussions.
When Victorio did not return home later that day, Felisa inquired about his whereabouts from Isidro, who claimed ignorance based on his recent travel and other family movements.

Initial police investigation by Investigator Eustaquio Mellilin, assisted by the National Bureau of Investigation, failed to establish a case due to the lack of substantive evidence.
Five years later in June 1975, an eyewitness, Morel Callueng—then eight years old—allegedly observed the murder in Iguig.

a. According to Callueng, while on his way to school, he heard moaning sounds near the Clores compound.
b. He climbed the concrete fence and saw Gavino Clores handling the victim, while Edmundo used a rifle’s butt to assault Victorio.
c. Isidro Clores was seen in the balcony, ordering his sons to finish the act and subsequently instructing them to carry the body away.

Callueng’s account included specific details on the method of assault and subsequent actions by the accused, despite his young age.

a. There was no motive to kill Victorio given the familial ties.
b. Their presence at the scene at the time of the alleged crime was denied by each through differing alibi accounts.

a. Edmundo Clores testified that he was in Quezon City working on a renovation contract with Atty. Virginia Tan—a fact supported by a contract and receipt proving his presence there on April 24, 1970.
b. Isidro Clores claimed that he had traveled to Manila, falling ill en route, and later verified by hospital records or travel manifests.
c. Gavino Clores stated that he was at his place of employment in the Municipal Treasurer’s Office during the time of the alleged incident.

a. There were conflicting statements regarding his exact actions—whether he climbed over the fence or simply peeped from behind it.
b. He varied his account on the position and state of the victim (standing or lying) during his initial observation.
c. His detailed recollection of the victim’s features and the incident’s minutiae raised doubts given his age and the six-year lapse before testifying.

Callueng also executed a sworn statement in 1979 retracting parts of his testimony, attributing the change to influence and coercion by law enforcement, though his subsequent explanations were equally inconsistent.
The overall narrative presented by Callueng did not align with common experience for a child of his age, further undermining his reliability.

Whether Morel Callueng’s testimony, given his age and the inconsistencies in his various accounts, can be accorded sufficient weight.
The impact of his delayed reporting and subsequent retraction on the overall credibility of the prosecution’s case.

Whether the identification by Callueng, despite its directness, is enough to meet the threshold of proof beyond reasonable doubt.
The role and strength of the alibi evidence presented by the appellants in challenging the prosecution’s narrative.

The issue of whether the absence of physical evidence (such as the sack, nylon rope, and corroborative witnesses besides Callueng) weakens the prosecution’s case.
Whether the allegations of politically motivated charges and personal disputes (e.g., the land dispute and influence of local figures) further cast doubt on the integrity of the investigation and subsequent testimony.

Whether the overall evidence suffices to achieve moral certainty as required in criminal cases to overcome the presumption of innocence.
The need to consider all circumstances that favor innocence before sustaining a verdict of guilt.