Title
People vs. Flora
Case
G.R. No. 125909
Decision Date
Jun 23, 2000
Two brothers, Hermogenes and Edwin Flora, convicted for double murder and attempted murder after a 1993 shooting at a party; alibi rejected, conspiracy proven.

Case Digest (G.R. No. 125909)
Expanded Legal Reasoning Model

Facts:

  • Background and Incident
    • On the evening of January 9, 1993, a birthday dance party was held in Sitio Silab, Barangay Longos, Kalayaan, Laguna.
    • Accused-appellants Hermogenes Flora (alias "Bodoy") and Edwin Flora (alias "Boboy") attended the party.
    • Emerita Roma (mother of Rosalie Roma), Ireneo Gallarte (neighbor), and Flor Espinas (aunt of Rosalie) were also present.
    • Around 1:30 a.m. on January 10, 1993, violence erupted; Hermogenes Flora fired two shots from a .38 caliber revolver.
      • First shot grazed Flor Espinas and fatally hit Emerita Roma.
      • Second shot hit Ireneo Gallarte, causing his immediate death.
    • Edwin Flora signaled Hermogenes by flicking a lighted cigarette and threatened eyewitness Rosalie Roma with a knife before fleeing with Hermogenes.
  • Legal Proceedings and Charges
    • Three separate informations were filed against the appellants for:
      • Murder of Emerita Roma (Criminal Case No. 4810).
      • Murder of Ireneo Gallarte (Criminal Case No. 4811).
      • Attempted murder of Flor Espinas (Criminal Case No. 4812).
    • Accused-appellants pleaded not guilty and were tried jointly before the Regional Trial Court, Branch 26, Santa Cruz, Laguna.
    • The trial court convicted both appellants for double murder (Emerita Roma and Ireneo Gallarte) and attempted murder (Flor Espinas) and imposed appropriate penalties and indemnities.
  • Autopsy and Medical Examination
    • Autopsy by medico-legal officer Dr. Ricardo R. Yambot, Jr. detailed fatal gunshot wounds on Emerita Roma and Ireneo Gallarte with causes of death attributed to hypovolemic shock due to massive blood loss.
    • Flor Espinas sustained gunshot wounds on right supra scapular and deltoid areas; medical certificate confirmed injuries that would have been fatal without timely medical treatment.
  • Witness Testimonies
    • Prosecution witnesses:
      • Rosalie Roma, eyewitness, who identified Hermogenes Flora as shooter and described the sequence of events.
      • Flor Espinas, injured victim who also identified appellants.
      • Felipe Roma (husband of Emerita Roma) and Matiniana Gallarte (widow of Ireneo Gallarte) testified on the victims’ ages, occupations, earnings, and burial expenses.
    • Defense witnesses:
      • Edwin Flora and Hermogenes Flora claimed alibi that they were not at the crime scene, supported by testimony of Imelda Madera, Edwin’s common-law wife.
      • Alibi was that Hermogenes was asleep at his sister's house about one kilometer from the scene.
  • Trial Court Decision
    • The trial court found appellants guilty beyond reasonable doubt based on positive identification and dismissed their alibi due to lack of corroboration and physical impossibility not proven.
    • Accordingly, both were sentenced to reclusion perpetua and ordered to pay indemnities and reparations respectively for each case.

Issues:

  • Whether appellants’ defense of alibi was sufficiently proven to cast reasonable doubt on their presence and guilt at the crime scene.
  • Whether the prosecution witnesses were credible and their testimonies reliable and sufficient to establish guilt beyond reasonable doubt.
  • Whether both appellants were criminally liable for the murder of Emerita Roma and the attempted murder of Flor Espinas in addition to the murder of Ireneo Gallarte.
  • Whether there was conspiracy between appellants for all the crimes charged or only on certain counts.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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