G.R. No. L-62617-18 - People vs. Colana y Avaricio

The prosecution, represented by the People of the Philippines, brought the case against Leonardo Colana y Avaricio, the accused-appellant.
Jorge Magabilen, a co-accused who was the president of the Phi Lambda Epsilon fraternity, was also convicted though he did not appeal.
Additional persons involved include Marcelino Caneda and Carlito Bravo, members of the fraternity and students, with Bravo later becoming a State witness.

The incident occurred on August 6, 1979, at about eight o’clock in the evening near the corner of Claro M. Recto Avenue and Oroquieta Street, close to the Manalili Bookstore in Manila.
The perpetrators – Magabilen, Colana, Bravo, and Caneda – waited for members of the rival Alpha Kappa Rho fraternity who were expected to pass by after class dismissal at the Far Eastern University (FEU).
A student, later identified as Librado de la Vega, was approached and attacked. Caneda identified him as belonging to the rival fraternity, setting the stage for the attack.

Magabilen initiated the attack by seizing De la Vega’s left arm, pushing him against a wall, and stabbing him.
Colana, armed with an icepick, joined in and inflicted additional stab wounds, a method consistent with the circular or punctured wounds found on the victim's body.
Although Bravo was present, his involvement was limited as he allegedly did not actively participate in the assault.
The victim, Librado de la Vega, sustained multiple wounds—seven in the chest (perforating his lung and heart), two on the right arm, and two on the left arm—leading to death by internal hemorrhage.

The killing was motivated by revenge stemming from a previous incident wherein members of the Phi Lambda Epsilon fraternity were reportedly beaten by members of the Alpha fraternity.
There was an underlying fraternity rivalry that provided the backdrop for the violent incident.

Key evidence included Colana’s confession (Exhibit A) taken during a custodial interrogation by Patrolman Reynaldo H. Jaylo on September 19, 1979.

The confession was made after Colana was reminded of his rights under the new Constitution, including the right to remain silent and the right to counsel.
Colana voluntarily signed a waiver confirming his understanding of these rights, opting to answer without legal assistance.

The confession specifically admitted that Colana assaulted the victim with an icepick, which was later shown to him by the investigating officer.
Additional documentary proof was offered with Colana’s signature on the Booking and Information Sheet (Exhibit D).
Testimony from Carlito Bravo aligned with his previous police statement (Exhibit O), reinforcing critical elements of the prosecution’s case.
Forensic evidence, particularly the characteristic punctured wounds on the victim, corroborated the use of an icepick as the murder weapon.

At trial, both Colana and Magabilen denied complicity, with Colana repudiating his earlier confession and both attempting to shift the blame onto Bravo and Caneda.
Despite these denials, the body of evidence, including the extrajudicial confession and testimonial as well as forensic findings confirming the nature of the wounds, led to a conviction.
The Circuit Criminal Court of Manila found both perpetrators guilty of murder and sentenced them to reclusion perpetua, also ordering the payment of indemnity to the victim’s heirs.

Whether Colana’s confession, made during custodial interrogation after being informed of his rights, was voluntary, intelligent, and therefore admissible.
Whether the waiver of constitutional rights under Article IV was valid and effective.

Whether the cumulative evidence, including forensic, testimonial, and documentary material, established Colana’s guilt beyond reasonable doubt.
Whether the denial of involvement at trial by Colana and the attempt to attribute the crime to other participants undermined the prosecution’s case.

Whether the trial court correctly imposed reclusion perpetua given the grave circumstances of the crime.
Whether the calculation and imposition of civil liability, including indemnity to the victim’s heirs, was justifiable based on the expenses incurred by the victim’s family.