Case Digest (G.R. No. 125966)
Facts:
People of the Philippines v. Juan Factao alias Boyet, Albert Francis Labroda alias Abet, and Tirso Servidad, G.R. No. 125966, January 13, 2004, Supreme Court Second Division, Tinga, J., writing for the Court.On the evening of August 23, 1991, Fernando Sardoma was in his kamalig in Barangay Sirawagan, San Joaquin, Iloilo, together with Eduardo Sardoma, Rolando Nierves, Noel Serrano and Vicente Manolos. While Vicente was beside a boat to defecate he observed Juan Factao and Albert Francis Labroda approach the hut; Factao carried a garand rifle. According to Vicente, Factao peeped into the hut, aimed the rifle through a hole in the bamboo wall and fired, after which Factao and Labroda ran toward the Sirawagan River. Jose Manuel Sermona separately testified that he saw the same two men approach and that Tirso Servidad passed with them but separated from them when they fled.
Inside the kamalig Eduardo, Rolando and Noel heard the explosion; Eduardo ran out, saw Servidad bending and wrapped his arms around him, and also saw Factao and Labroda running away. Fernando was found bleeding and was rushed to the hospital but was dead on arrival. The hospital autopsy by Dr. Irene Escanlar showed a gunshot wound with massive internal injuries; death resulted from hypovolemic shock.
Police arrested Factao, Labroda and Servidad and charged them with Murder in an Information alleging treachery and evident premeditation. At trial the prosecution presented testimony of Vicente Manolos, Jose Manuel Sermona, Eduardo Sardoma and Dr. Escanlar. The three accused pleaded not guilty and each invoked alibi. Factao and Labroda, both CAFGU members, testified they were celebrating Labroda’s birthday at Labroda’s house until about 10:00 p.m., a fact partially corroborated by Noel Lupase. Servidad, also a CAFGU member, testified he met Barangay Captain Faustino Nierves at about 8:30 p.m., was asked to investigate an explosion, saw people at the scene, helped summon assistance and went home; Captain Nierves corroborated meeting Servidad.
On July 14, 1995, the Regional Trial Court (RTC), Iloilo City, Branch 25, found all three guilty of Murder and sentenced them to reclusion perpetua, ordering indemnities and funeral and attorney’s fees. The accused appe...(Pro-only)
Issues:
- Did the prosecution establish beyond reasonable doubt that Juan Factao and Albert Francis Labroda committed the murder of Fernando Sardoma?
- Did the prosecution establish beyond reasonable doubt that Tirso Servidad committed the murder of Fernando Sardoma?
- Were the alleged aggravating circumstances—treachery, evident premeditation, nighttime, and dwelling—present, and what is the proper penalty?
- Are the awards of civil indemnity, exemplary and temperate damages, and...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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