People vs. Cordova

Facts:

People of the Philippines v. Reynaldo Cordova @ "Rey" Cordova, Eduardo Cordova @ "Suli" Cordova, Isidro Cordova, Jr. @ "Drobat," Freddie Buenconsejo @ "Odong," and Ernesto Estorque, Jr., G.R. Nos. 83373-74, July 05, 1993, Supreme Court Third Division, Davide, Jr., J., writing for the Court.

On the evening of 29 May 1986, Marcelo Barruela and Segundo Maguad were killed in Barangay Bantigue, Pontevedra, Capiz. Following a complaint by Marcelo’s widow Teresita, Criminal Case No. 705 for double murder was filed with the 2nd Municipal Circuit Trial Court (MCTC) of Pontevedra-Panay on 16 June 1986; after preliminary examination the MCTC found probable cause against the accused (except Clarita Cordova). Arrest warrants issued, the accused were arrested and the records were transmitted to the Office of the Provincial Fiscal for possible filing of informations.

Acting Provincial Fiscal Claro A. Arches reinvestigated and filed two separate informations for murder on 29 January 1987 with the Regional Trial Court (RTC) of Roxas City: Criminal Case No. C‑2422 (for Marcelo Barruela) and Criminal Case No. C‑2423 (for Segundo Maguad). The accused pleaded not guilty at their arraignment on 11 March 1987. The prosecution presented six primary witnesses (including Rodolfo Maguad, Teresita Barruela, Norberto Javier, Dr. Salvador Billones, Pat. Rafael Dipon, and Pfc. Allan Contreras) and several rebuttal witnesses; the defense presented the accused and thirteen other witnesses.

Prosecution witnesses described unknown men calling Marcelo as “Tay Seloy” and introducing themselves (one as “Richard de la Torre”), then one identified as Reynaldo allegedly fired rapid shots causing Marcelo’s death; Rodolfo and Teresita gave accounts identifying Eduardo and Reynaldo Cordova among those present. Norberto Javier placed five named persons on a motorboat earlier that evening. Several accused gave alibi testimony and others denied involvement; thirteen‑year‑old Ernesto Estorque, Jr. admitted being on the motorboat but denied knowledge of any killings.

The RTC (Branch 16, Roxas City) rendered a decision dated February 1988 convicting Reynaldo and Eduardo Cordova as principals of murder (both informations) and finding Ernesto Estorque, Jr. an accessory after the fact (with minority as mitigating circumstance); Isidro Cordova and Freddie Buenconsejo were acquitted. The court relied principally on the identification testimony of Rodolfo, Teresita and Norberto, and found treachery and evident premeditation present. The convicted accused appealed to th...(Pro-only)

Issues:

• Did the trial court err in crediting the prosecution witnesses and in rejecting the appellants’ alibi and other exculpatory evidence?
• Was the prosecution’s evidence sufficient to convict Reynaldo and Eduardo Cordova as co‑principals and Ernesto Estorque, Jr. as an accessory beyond reasonable doubt?
• Were treachery and evident premeditation established to justify the qualifying circumstances attached to the murder convictions?
• Did the trial court err in refusing to accept appellant Ed...(Pro-only)

Ruling:

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Ratio:

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Doctrine:

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