Case Digest (G.R. No. 100724)
Facts:
People of the Philippines v. Narciso Evardo y Juan, G.R. No. 100724, December 01, 1992, the Supreme Court Third Division, Bidin, J., writing for the Court. The plaintiff-appellee is People of the Philippines; the accused were Narciso Evardo y Juan (appellant), Efipanio Evardo y Juan, Tambi Ladja y Antisan and an unidentified John Doe.On or about September 18–19, 1987, Ricardo Mendoza y Concepcion (father) and Robert Mendoza y Alejandro (son) disappeared after accompanying Narciso and Efipanio Evardo to nearby isles; their bodies were later found in a vinta, and Ricardo’s government-issued Garand rifle was missing. The police investigation produced photographs of the bodies, the discovery of a wooden paddle found in the vinta, and reports that Narciso was apprehended near a ricefield armed with a scythe and that Marcelina and Vilma Mendoza identified the vinta as the one in which the bodies were found. Police Investigator Cresencio Guevarra prepared initial and final reports and testified that Narciso admitted to participating in the killings before the investigating fiscal.
The Regional Trial Court of Zamboanga City tried the case for Robbery with Double Homicide. Two co-accused (Efipanio and Tambi) died before trial; John Doe remained unidentified. The RTC found Narciso guilty beyond reasonable doubt as principal of Robbery with Double Homicide, sentenced him to reclusion perpetua, ordered indemnity amounting to P60,000.00 to the heirs, and credited detention time. Narciso appealed.
On appeal, Narciso argued that the conviction rested on circumstantial evidence only; he disputed the trial court’s findings that he (a) invited the victims to Kabog Island, (b) owned the vinta where the bodies were found, (c) attempted to manufacture an alibi, and (d) was motivated by association with the MNLF because he was a Muslim convert. He also presented affirmative defenses: that he was working in Basilan prior to the killings, that he and companions were tortured by CHDF members, and that medico-legal records showed injuries cons...(Subscriber-Only)
Issues:
- Was the conviction for Robbery with Double Homicide supported by sufficient circumstantial evidence beyond reasonable doubt?
- Was the evidence sufficient to sustain conviction for two counts of homicide?
- Did appellant’s defenses of alibi, denial and alleged torture defeat the prosecution’s case or otherwise justify acquittal or reversal?
- Could the trial court properly infer motive and MNLF membership from appellant’s status as a Muslim convert and use tha...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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