Facts:

The cases at hand involve several accused persons, namely Diego Colman, his sons Rogelio and Reynaldo Colman, Irineo Lisondato, Francisco Pogon, and Alfredo Pilota, charged with multiple murders and a frustrated murder concerning the killings of Antonio Mainar, Thelma Ganzon, and Elizabeth Ganzon, as well as the attempted murder of Carolina L. Ganzon. The events date back to January 7, 1952, in Pototan, Iloilo, where Buenaventura Ganzon, the owner of a ricemill, had previously dismissed Diego Colman from his employment as a watchman due to deteriorated relations and alleged misconduct towards Ganzon's family, including derogatory remarks and intentions of violence.

On the night of the incident, after replacing Colman with a new watchman, Alfredo Cardinales, Buenaventura Ganzon and his family were subjected to an attack. A premeditated shooting occurred, during which his daughters, Thelma and Elizabeth, both minors, were fatally shot, along with Antonio Mainar, who was also

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Facts:

Background and Employment Relationship

• Buenaventura Ganzon owned a ricemill in Pototan, Iloilo.
• From 1949 until around December 15 or 20, 1951, he employed his neighbor Diego Colman as his watchman.
• The residences of both men were very close (only 7 meters apart) on the same side of San Jose Street, near the railroad track.

Deterioration of Relations and Pre-Incident Circumstances

• Tensions had arisen between Buenaventura Ganzon and Diego Colman, with Colman believing his dismissal was imminent.
• Colman had reportedly slandered his employer by saying he was “back-biting” and even accused him of planning to rape one of Ganzon’s daughters.
• Additionally, there was a known association with Alfredo Pilota, who was also implicated as belonging to the same gang as Diego Colman.

The Events of January 7, 1952 – Initial Developments

• On January 7, 1952, Ganzon replaced Colman with a new watchman, Alfredo Cardinales.
• At approximately 7 o’clock in the evening, Rogelio Colman appeared at Ganzon’s premises. Cornelio Parreno later arrived, conveying instructions on Diego Colman’s orders for Cardinales to visit Diego’s house.
• Despite Ganzon’s repeated advice that Cardinales remain indoors, increasing agitation was observed around the house.

The Incident During the Night

• At around 8 o’clock, sounds of shouting and dialect—believed to be related to remarks about reliance on Ganzon—alerted him.
• Observing Diego Colman, Domingo Mainar, and Rogelio Colman (the latter armed with a long bolo) moving suspiciously near his residence heightened Ganzon’s alarm.
• Colman then summoning his two sons (Rogelio and Reynaldo) and other conspirators to execute a planned violent attack became evident as Ganzon tracked their movements.

The Shooting and Aftermath at the Ganzon Residence and Nearby

• Shortly after 10:15 p.m., while Ganzon was in bed with his family, rapid gunshots were fired at the watchman’s quarters and subsequently toward the room where his family was sleeping.
• In response, Ganzon, displaying quick thinking, took steps to protect his family:
• He moved his baby boy to safety, advised his wife and daughters to lie down with protective objects such as mattresses and trunks, and prayed.
• He took up his flashlight and pistol, went outside cautiously, and engaged in a brief gun duel with Damaso Ferraris—hitting him—and then sought medical aid.
• Concurrently, further violence ensued when shots were directed at the house of Domingo Mainar, resulting in injuries and a subsequent fatality when Mainar’s son, Antonio, was struck.
• The sequence of events was supported by testimonies of several witnesses, including accounts by Domingo Mainar and others who observed Diego Colman and his companions in various stages of the assault.

Involvement of Additional Persons and Subsequent Movements

• Other individuals such as Irineo Lisondato, Francisco Pogon, and Alfredo Pilota were implicated:
• Francisco Pogon and Ireneo Lisondato were seen near a mahjong game prior to being recruited for other tasks by Diego Colman.
• Pilota, initially charged in connection with other accusations, later changed his plea to guilty and was sentenced separately.
• It was established that the attackers had planned their positions along the railway area and at other strategic locations before launching coordinated attacks.
• The instructions from Diego Colman explicitly mentioned eliminating Ganzon, his watchman, and even his animals.

Judicial Proceedings and Charges Filed

• Four separate informations were filed with the Court of First Instance of Iloilo:
• Case No. 3165 – for the murder of Antonio Mainar.
• Case No. 3166 – for the murder of Thelma Ganzon.
• Case No. 3167 – for the murder of Elizabeth Ganzon.
• Case No. 3168 – for the frustrated murder of Carolina L. Ganzon (the mother).
• The cases were tried jointly. The prosecution secured the discharge of accused Francisco Pogon so that he could serve as a government witness.
• After evidence was presented, Alfredo Pilota pleaded guilty and received a separate sentence.
• The trial continued with Diego Colman, his sons Rogelio and Reynaldo Colman, and Irineo Lisondato as the main defendants.

Trial Court Findings and Subsequent Appellate Review

• The trial court found:
• In Case No. 3165, Diego, Rogelio, and Reynaldo Colman were guilty as principals in the homicide of Antonio Mainar—with aggravating circumstances of treachery, nocturnity, and dwelling—with Diego Colman sentenced to death and his sons to reclusion perpetua.
• In Case No. 3166, similar findings were made for the murder of Thelma Ganzon, with Diego and Rogelio Colman sentenced to death and Reynaldo to reclusion perpetua.
• In Case No. 3167, the murder of Elizabeth Ganzon resulted in the same penalties as above.
• In Case No. 3168, they were found guilty of frustrated murder of Carolina L. Ganzon with indeterminate penalties imposed.
• The accused Irineo Lisondato was acquitted in all four cases due to insufficient evidence against him.
• On appeal, the Court of Appeals reviewed these three main cases (Nos. 3165, 3166, and 3167) focusing primarily on:
• Whether the convictions and imposition of the death penalty on Diego Colman and Rogelio Colman were legally and factually supported.
• The validity of the aggravating circumstances, including treachery, dwelling, and the alleged evident premeditation.
• The contention by counsel regarding issues of conspiracy, inadequate defense evidence, procedural irregularities, and double jeopardy.

Issue:

Determination of Guilt and Participation

• Whether the evidence sufficiently established that Diego Colman and Rogelio Colman were co-conspirators and principals in the commission of the multiple murders and frustrated murder.
• Whether the act of engaging in "indiscriminate shooting" and the coordinated attack on the houses of the Ganzons and Mainars was conclusively attributable to the accused.

Application of Aggravating Circumstances

• Whether the trial court correctly applied and found the qualifying circumstance of treachery and the aggravating circumstance of dwelling.
• Whether the element of evident premeditation was rightfully considered or waived due to the limited time between the planning and execution of the crimes.

Procedural and Constitutional Issues

• Whether the alleged mishandling of arraignment—in particular, the claim that the accused were arraigned in the Justice of the Peace Court without their counsel—and the filing of new informations after a not-guilty plea violated due process rights.
• Whether the failure to properly arraign in the Court of First Instance affected the validity of the subsequent convictions.

Consideration of the Defense Evidence

• Whether the trial court improperly favored the prosecution’s evidence by not affording adequate weight to the defense’s presentation, including the defense of alibi.
• Whether the credibility determinations made by the trial judge regarding the witnesses’ testimonies were just and supported by the evidence.

Double Jeopardy Concerns

• Whether the separate filing of informations for the crimes against different victims constituted a violation of the double jeopardy rule.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Evidentiary Determinations and Credibility of Witnesses

• The trial judge’s determinations of witness credibility and the factual inferences drawn from their testimony were accorded deference on appeal, unless clear material errors were present.

• The absence of any direct negation of the prosecution’s established facts meant that the circumstantial evidence was sufficient to support the convictions.

Establishment of Conspiracy

• The case reaffirmed that a conspiracy does not require direct evidence of an agreement; it can be inferred from the collective acts of the accused working toward a common unlawful purpose.
• The doctrine that the act of a co-conspirator is attributable to all participants was a key basis in upholding the convictions.

Aggravating and Qualifying Circumstances

• Treachery and dwelling as aggravating circumstances were deemed sufficient to justify the imposition of the death penalty, even in the absence of what was characterized as “evident premeditation.”
• The analysis explained that the limited period between the employment of a new watchman and the execution of the crimes did not allow for significant contemplation that would mitigate the severity of the charges.

Procedural Due Process and Arraignment Issues

• The court held that arraignmen

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