Facts:

On August 17, 1967, a complaint for murder was filed against Diego Estrada, Juanito Estrada, and Luis Estrada in the Municipal Court of Gubat, Sorsogon. After a preliminary examination of witnesses, the court ordered their arrest, setting a bail of P20,000 each. The trio was arrested but failed to post bail. On August 25, 1967, they waived their right to a preliminary investigation, leading to the case being elevated to the Court of First Instance of Sorsogon, where it was assigned Criminal Case No. 3865. Initially, on September 15, 1967, an assistant provincial fiscal filed a motion to provisionally dismiss the case, citing insufficient evidence. This motion was granted, resulting in the release of the accused.

However, on May 23, 1968, the case was revived with the filing of an information for murder against the Estradas, documented as Criminal Case No. 400. The information alleged that on August 9, 1967, the accused, armed with clubs, attacked the victim, Romeo Escurel, resul

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Facts:

Procedural Background

• A complaint for Murder was filed in the Municipal Court of Gubat, Sorsogon against Diego Estrada, Juanito Estrada, and Luis Estrada.
• After preliminary examination of witnesses, the Municipal Court ordered the arrest of the accused and fixed bail at P20,000.00 each, but the accused did not post bail.
• On August 25, 1967, the accused waived their right to a preliminary investigation, prompting the elevation of the case to the Court of First Instance of Sorsogon (Criminal Case No. 3865).
• The assistant provincial fiscal filed a motion for provisional dismissal on the ground that a diligent perusal of the evidentiary record indicated insufficient evidence to warrant a conviction. This motion was granted, and the accused were released.
• On May 23, 1968, an information for Murder (Criminal Case No. 400) was filed reviving the case against the three Estradas.

Charges and Allegations

• The information alleged that on or about August 9, 1967, in the Municipality of Gubat, the accused, conspiring and confederating with one another, intended to kill Romeo Escurel.
• The accused were said to be armed with a club and lead pipe and, with superior strength, delivered blows to different parts of Romeo Escurel’s body, both from behind and in front.
• After the assault, they allegedly dumped his body into a well to conceal the crime, resulting in his instant death.
• Only Diego Estrada was tried because his two sons, Luis and Juanito, fled the jurisdiction soon after the earlier dismissal, with an alias order of arrest failing to bring them to court.

Factual Narrative of the Crime

• The People’s version states that on the evening of August 9, 1967, Romeo Escurel and his friend Romulo Endaya, after drinking Tanduay Rhum at a local store in the marketplace, were involved in a confrontation.
• Luis Estrada—nicknamed “Oyet”—and his companions, already drunk, followed and provoked the two friends.
• A fist fight ensued; initially, Escurel and Endaya attempted to continue their peaceful night.
• Subsequent accounts describe that:
• As Escurel and Endaya left the store around 9:00 p.m., they were chased and engaged in a physical altercation with the suspect group.
• Witness testimonies (including those of tricycle drivers and policemen) detailed that Escurel was seen pummelled by Diego, Luis, and Juanito Estrada and was later found dead, dumped inside a well.
• The autopsy established:
• Multiple abrasions, hematomas, and puncture wounds consistent with blunt force trauma from clubs and fists.
• The cause of death was asphyxia due to drowning secondary to shock, with the body in a “rigor mortis” state upon retrieval.

Investigative and Trial Details

• On August 16, 1967, investigations by the Philippine Constabulary led by Sgt. Silvestre Espedido processed the statements of the accused, including a signed refusal of Diego Estrada to endorse his written statement.
• Witnesses such as Policarpio, Estocado, and Tapia provided detailed testimonies recounting their observations of the incident and the whereabouts of the accused during and after the crime.
• Diego Estrada’s statement, which contained elements resembling an extra-judicial confession, was recorded and discussed during the investigation and trial.
• The trial court noted that Luis and Juanito fled the province after the initial dismissal, remarking that their flight might indicate a troubled conscience, though this was a passing remark not used to directly implicate Diego.

Judgment at Trial

• The trial court found Diego Estrada guilty beyond reasonable doubt of the crime of Murder.
• He was sentenced to reclusion perpetua, ordered to indemnify the legal heirs of Romeo Escurel in the amount of P12,000.00, and to pay one-third of the costs.
• The trial court’s findings rested on the strength of the circumstantial evidence and the corroborated testimonies of multiple witnesses.

Issue:

Alleged Errors in the Trial Court’s Findings

• Whether it was erroneous for the trial court to find that Luis and Juanito Estrada had fled the jurisdiction, thereby implying a troubled conscience on their part.
• Whether the trial court erred in attributing the provocation of the fight to the accused and his companions as per the uncontradicted testimony of Romulo Endaya.
• Whether improper credence was given to the testimonies of key prosecution witnesses such as Espiridion Policarpio, Marianito Estocado, and Policarpio Tapia, considering their minor inconsistencies.

Evaluation of Evidence and Admission

• The admissibility and probative value of the extra-judicial confession in Diego Estrada’s statement, noting that its lack of an explicit admission of guilt was still taken as pertinent when combined with other evidence.
• The sufficiency of evidence against Diego Estrada, especially in light of his attempted alibi and the fact that his co-accused were not available for trial.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)