G.R. No. L-23202 - People vs. Elizaga

On August 20, 1963, an information for murder was filed in the Court of First Instance of Cagayan.
The accused included Romarico Elizaga, Cresencio Elizaga, Venerando Tobias, Carlito Cabiera, Jaime de la Cruz, Vicente Cortes, and Grevel Galindon (the latter later acquitted).
The information alleged that the accused, in concert and with evident premeditation and treachery, conspired and shot Rodolfo Paulino, causing a fatal gunshot wound to the middle third of his arm resulting in hemorrhage.

On the night of June 26, 1963, Antonio Singson, his wife, and other occupants were in his house at Abariungan Ruar, Faire, Cagayan.
During a conversation inside the house, gunfire erupted from outside, initiated by a group of six persons.
Witness testimony (including that of Singson himself) indicated that the assailants fired upon the house; Rodolfo Paulino, present outside the house during the exchange, was fatally shot.
PC soldiers subsequently apprehended several persons fleeing the scene, including those later identified as the appellants.

Testimonies by constabulary personnel (Cpl. Elias Soriano, Cpl. Leon Bumagat, and others) detailed the sequence of events:

The soldiers heard gunfire and observed persons running from the vicinity of Singson’s house toward the river bank.
The apprehended individuals were seen boarding a motor-banca where one, Vicente Cortes, was discovered wounded.

Subsequent investigation led to the recovery of firearms from the river based on the confession of Cresencio Elizaga that the accused had disposed of their weapons into the water.

Cresencio Elizaga and Gaspar Casili were the only ones who gave statements immediately after apprehension, while other accused remained silent.
Cresencio’s confession detailed the movement of the accused from a jeep ride to a motor boat ride to the house of Romarico Elizaga at Abariungan Ruar, followed by the raid on Singson’s house.
The confession was supported by physical evidence (retrieved firearms) and was corroborated by the sequence of events as testified by PC personnel and other witnesses.
Cresencio later attempted to repudiate his confession alleging that it was extracted by force and intimidation; however, evidence—including the presence of the justice of the peace and corroborative testimony—countered this claim.

Prior to the incident, there existed a strained relationship between Romarico Elizaga and Antonio Singson stemming from previous legal cases involving frustrated murder and grave threats.
Business competition in the ferryboat operations across the Cagayan River further heightened animosity between Romarico Elizaga and Singson.
The prior conflict served as a motive and contributed to the escalated tension that culminated in the raid on the house.

Romarico Elizaga was identified as the apparent leader by witnesses such as Singson and the PC personnel.
Cresencio Elizaga, Jaime de la Cruz, and Vicente Cortes were present with Romarico during the exchange of gunfire.
Venerando Tobias and Carlito Cabiera were recorded as being present at the scene but their participation in the crime was not clearly established by the evidence.

Testimonies, including those of defense witnesses, described the actions of the accused before, during, and after the incident, with substantial circumstantial evidence linking them to the fatal shooting of Rodolfo Paulino.

Whether the evidence sufficiently established that the appellants present at the scene were indeed the persons who fired at Singson’s house.
Whether the recognition of Romarico Elizaga as the leader and the identification of his companions is based on credible eyewitness testimony or mere assumption due to their apprehension by the PC soldiers.

Whether Cresencio Elizaga’s confession, later challenged on the grounds that it was obtained through force and intimidation, was voluntary and reliable.
Whether the absence of corroborative medical findings of alleged injuries on Cresencio Elizaga sufficiently refutes his claim of maltreatment.

Whether the chain of circumstantial evidence—ranging from eyewitness accounts, physical evidence (retrieved firearms), and the sequence of events—establishes the guilt of the appellants beyond reasonable doubt.
Whether the movements of the accused, as documented in the evidence, adequately connect them to the act of shooting that resulted in Paulino’s death.

Whether the participation of certain accused (specifically Venerando Tobias and Carlito Cabiera) was clearly proven, given that they appeared to merely follow the group rather than actively engage in the shooting.
How the evidence supports the varying degrees of criminal responsibility among the accused.