G.R. No. 172131 - Vinzons-Chato vs. Commission on Elections

Three separate Informations were filed against accused-appellant Joel Domingo and co-accused Roel Domingo in Criminal Cases Nos. 11741-14, 11742-14, and 11743-14.
The charges include two counts of Murder and one count of Attempted Murder, with each case alleging that the accused, in concert with others, committed the crimes through conspiracy, treachery, and evident premeditation.
The incidents occurred on the evening of February 26, 2005, at different sites within Barangay Sta. Maria in the municipality of Piddig, Ilocos Norte.

In Criminal Case No. 11741-14, the Information alleges that Joel Domingo shot Virgilio Dalere with an unlicensed firearm, causing his instantaneous death.
In Criminal Case No. 11742-14, the same set of allegations is made concerning the shooting of Glenn Rodriguez, which similarly resulted in death.
In Criminal Case No. 11743-14, the accused is charged with attempting to murder Roque Bareng, wherein the assailants assaulted Bareng but failed to hit him, despite executing overt acts that commenced the commission of Murder.

Initially, the cases were raffled to Branch 15 of the Regional Trial Court (RTC) of Laoag City, where both accused pleaded not guilty.
Accused-appellants moved, through counsel, for re-raffling of the cases due to delays in pretrial proceedings; consequently, the cases were reassigned to Branch 14.
At the pretrial conference, both parties agreed that the prosecution would present its evidence in four scheduled settings.

The prosecution failed to appear with a single witness during the four agreed-upon settings.
On February 7, 2007, the RTC issued an Order dismissing the cases for failure of the prosecution to present evidence, and directed the immediate release of the accused.
Later, the Office of the Provincial Prosecutor filed a Motion for Reconsideration citing the lack of proper service of subpoenas to witnesses who reportedly moved due to threats.
On June 14, 2007, the RTC granted the Motion for Reconsideration, thereby ordering the re-arrest of accused-appellant Joel Domingo, while the cases against Roel Domingo were eventually dismissed due to his death.

The prosecution relied solely on the testimony of private complainant Roque Bareng, whose account detailed the sequence of events, the entry of armed men, and the ensuing shootout.
Bareng’s testimony, however, was marked by material inconsistencies regarding the number of shots fired, the timing of actions, and the physical descriptions of the assailants.
The defense presented an alibi, substantiating that Joel Domingo was attending a social dance in Brgy. Dupitac on the night of the incident, a claim corroborated by multiple defense witnesses, including Norman Pablo and Barangay Chairman Noel Esteban.

The RTC’s Joint Judgment convicted Joel Domingo on the charges in Criminal Cases Nos. 11741-14, 11742-14, and 11743-14, with corresponding penalties and orders for the payment of damages to the victims’ families and complainant.
The Court of Appeals (CA) affirmed the RTC’s Joint Judgment with modifications—in particular, slight increases in the amounts for exemplary damages and changes in the penalty range for the attempted murder charge.
Accused-appellant then appealed from the CA decision, raising issues related to the procedural delays and questions regarding the sufficiency and consistency of the prosecution’s evidence.

Whether the trial court’s action in dismissing the cases—based on the prosecution’s failure to present evidence during the four scheduled settings—violated the accused-appellant’s constitutional right to a speedy trial.
Whether, by subsequently reconsidering the dismissal and re-arresting the accused, the trial court subjected him to double jeopardy.

Whether the sole testimony of private complainant Roque Bareng was sufficiently credible to prove the guilt of the accused beyond reasonable doubt.
Whether the discrepancies and inconsistencies in Bareng’s testimony, when weighed against the evidence of defense witnesses establishing an alibi, render the prosecution’s case fatally weak.