Case Digest (G.R. No. 196005)
Facts:
People of the Philippines v. Charlie Fieldad, Ryan Cornista, and Edgar Pimentel, G.R. No. 196005, October 01, 2014, Supreme Court Second Division, Carpio, Acting C.J., writing for the Court.The accused-appellants — Charlie Fieldad, Ryan Cornista, and Edgar Pimentel — were charged in three informations for (1) the murder of JO2 Reynaldo Gamboa (Criminal Case No. U-10053), (2) the murder of JO1 Juan Bacolor, Jr. (Criminal Case No. U-10054), and (3) carnapping of a Tamaraw jeep (Criminal Case No. U-10055). The informations alleged that on the morning of 9 March 1999 inmates conspired, armed themselves with unlicensed firearms, killed two jail guards inside the BJMP compound in Urdaneta City, and escaped using the Tamaraw jeep (Plate CDY-255) owned by Benjamin Bauzon.
At trial the prosecution presented numerous witnesses, including jail personnel and forensic witnesses, who described how JO2 Gamboa, JO1 Bacolor and JO2 Niturada were at the nipa hut for routine duties when inmates, including the accused and others, attacked. Witness Dionisio Badua positively identified Fieldad and Cornista grappling for Bacolor’s armalite and related that Fieldad obtained JO2 Gamboa’s pistol and shot Bacolor. Autopsies by Drs. Parayno and Gonzales established fatal gunshot injuries. Forensic paraffin tests on Fieldad’s hands were positive for gunpowder nitrates. Several inmates, including appellants, boarded the Tamaraw jeep and later transferred to a Mazda pick-up; police eventually arrested the group after the pick-up overturned in Tarlac.
The Regional Trial Court of Urdaneta City rendered a Joint Decision on 3 November 2008 convicting Fieldad, Cornista and (in the carnapping case) Pimentel: in U-10053 and U-10054 it found Chan, Fieldad and Cornista guilty of murder (reclusion perpetua) and acquitted several co-accused including Pimentel for the murder counts; in U-10055 it convicted Fieldad, Cornista and Pimentel of carnapping and acquitted others. The trial court fixed awards for civil indemnity, moral, exemplary and actual damages, and loss of earning capacity.
Fieldad, Cornista and Pimentel appealed to the Court of Appeals. The Court of Appeals, in a Decision dated 22 October 2010 (CA–G.R. CR–H.C. No. 03943), affirmed with modification only as to Cornista’s penalty for murder — reducing reclusion perpetua to a term reflecting the privileged mitigating circumstance of minority — and otherwise affirmed the trial court’s findings. Cornista later withdrew his appeal, rendering his convictio...(Pro-only)
Issues:
- Did the prosecution prove the guilt of appellants beyond reasonable doubt?
- Were the killings of JO2 Gamboa and JO1 Bacolor committed with treachery and pursuant to conspiracy?
- Was Ryan Cornista entitled to privileged mitigation by reason of minority?
- Were appellants justified in taking the Tamaraw jeep under the defense of u...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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