G.R. No. 196735 - People vs. Feliciano, Jr.

The People charged twelve (12) members of the Scintilla Juris Fraternity—Danilo Feliciano, Jr., Julius Medalla, Christopher Soliva, Warren Zingapan, Robert Alvir, Reynaldo Ablanida, Carlo Fajardo, George Morano, Raymund Narag, Gilbert Magpantay, Benedict Guerrero, and Rodolfo Peñalosa, Jr.—with murder (Criminal Case No. Q95-61133) and related counts of frustrated and attempted murder for the death of Dennis Venturina and injuries to Sigma Rho Fraternity members.
The informations alleged conspiracy, treachery, premeditation, superior strength, and disguise (masks or other forms of concealment) as aggravating circumstances.

Between 12:30–1:00 PM at the UP Diliman Beach House Canteen, seven Sigma Rho members—Venturina, Lachica, Natalicio, Mangrobang, Gaston, Fortes, and Tumaneng—were eating lunch when a group of some fifteen masked men armed with baseball bats and lead pipes charged them.
Victims scattered; Dennis Venturina was struck on the head and body, sustaining fatal injuries. The other five were beaten, suffering contusions, lacerations, and fractures requiring hospitalization.

Prosecution eyewitnesses (Lachica, Natalicio, Mangrobang, Gaston, Fortes) testified they recognized certain assailants—Alvir, Zingapan, Medalla, Soliva, and Feliciano—when masks fell off or were never worn.
Defense and bystander witnesses (UP police officers Cabrera and Salvador; canteen workers; sorority sisters) testified that all attackers remained masked and unidentifiable; none saw masks fall off.

Dr. Rolando Victoria’s autopsy on Venturina: multiple head contusions, skull fractures, intracranial hemorrhage—cause of death was traumatic head injury by a hard, blunt object.
Dr. Aurelio Villena’s medico-legal exams: victims sustained lacerations, contusions, abrasions, and fractures requiring 10–30 days of medical attention.

The Regional Trial Court (Branch 219, QC) tried eleven (11) accused (one at large) from 1995 to 2002. Peñalosa was dismissed on demurrer to evidence. In February 2002 the RTC convicted Alvir, Feliciano, Soliva, Medalla, and Zingapan of murder and attempted murder; acquitted Ablanida, Fajardo, Magpantay, Morano, and Narag; Guerrero’s case was archived.
The Court of Appeals (Special First Division) in 2010 affirmed (3–1) the RTC decision, convicting the same five appellants. The Supreme Court took up the case in 2014 on issues of information sufficiency and identification credibility.

Did alleging “wearing masks and/or other forms of disguise” in the information violate the accused’s right to be informed of the nature and cause of the accusation?
Could the prosecution nonetheless present evidence that some masks fell off without rendering the information deficient?

Were the victims’ positive identifications of specific accused reliable beyond reasonable doubt despite inconsistencies, brief duration of the incident, and testimony that all assailants were masked?
Did delay in naming the attackers to UP police and the Infirmary doctors—followed by affidavits at the NBI four days later—undermine the credibility of their identifications?

Was conspiracy proved to attribute co-principal liability to all accused regardless of individual participation?
Were distinctions among murder, frustrated murder, attempted murder, and slight physical injuries correctly applied to each accused’s actions?