G.R. No. L-24371 - People vs. Guevarra

The case involves the People of the Philippines as the plaintiff-appellee and Constancio Guevarra as the defendant-appellant, charged with murder.
The incident occurred on November 12, 1959, in the municipality of Naujan, Oriental Mindoro, amid political tensions following a local election.
A group of policemen, including Constancio Guevarra, Felipe Cornelio, Estelito Frayre, Gregorio Mercado, Jugo Fajardo, and Yolando Sarabia, were involved in the events leading to the crime.

In the late afternoon of November 12, 1959, the group went to the house of Mayor Amando Melgar in barrio San Jose No. 2, Naujan, to inquire about benefits due to pending resignations after the defeat of Mayor Melgar in the elections.
While gathering at the store owned by Sgt. Garchico (in front of the Mayor's house), they consumed wine and discussed a rumor from barrio Inarawan, which implicated Andres Papasin in allegations against the police force and contributed to the mayor’s electoral defeat.
During the discussion, Felipe Cornelio and Estelito Frayre volunteered to visit Papasin’s residence to clarify the rumor, reflecting a general atmosphere of resentment against Papasin.

Cornelio and Frayre proceeded to Papasin’s house, despite opposition from Yolando Sarabia who tried to dissuade them. Papasin, upon their arrival, invited them in, and a discussion ensued regarding the rumor attributed to him.
While inside Minerva Montejo’s store (located near Papasin’s house), a heated exchange occurred between Cornelio and Papasin. Frayre’s discontent was manifest when he bluntly exclaimed, “Tirahin na iyan,” signaling a potential for violence.
Constancio Guevarra, who had joined at the gate and was later seen inside the store area, drew his .45-caliber service pistol. Although an accomplice (Amado Garing) briefly intervened by grabbing the gun, the tension escalated.

After Papasin and his wife left the store, the group disbanded and returned to other parts of the town. Guevarra, having indicated that he was heading to the poblacion, later retraced his steps.
Guevarra stopped under a tamarind tree near Papasin’s house—approximately 20 meters from Papasin’s residence—to await his chance.
Agapito Salazar, a cousin of Papasin and mistaken by Guevarra for Papasin, was encountered about 15 meters away from Guevarra’s position.
Guevarra fired his service pistol: initially at a distance of about 14 meters and then, after moving closer (approximately 6 to 8 meters away), fired two additional shots.
Salazar fell as a result of the gunshot wound induced by these consecutive shots.

Following the shooting incident, Guevarra fled the scene; in his hasty retreat he struck his head against a guyabano tree, sustaining a noticeable forehead injury.
Instead of immediately reporting his actions, he sought refuge by entering the house of his godfather in marriage, Mayor Melgar, through a back door, avoiding the direct approach to the mayor’s main area.
Investigative procedures were promptly undertaken by the police, including the collection of eyewitness testimonies and the autopsy performed by Dr. Edith Panganiban confirming the cause of death as an acute circulatory and respiratory failure due to a non-penetrating gunshot wound at the neck.
The following day, Guevarra and his associates were brought in for questioning. Guevarra executed an extra-judicial confession (Exhibit A), admitting that he shot Agapito Salazar, having mistaken him for Andres Papasin.

The defense challenged the credibility of eyewitnesses, namely Yolando Sarabia, Gregorio Mercado, and Antonio Valencia, asserting discrepancies in distances and the ability to accurately identify the shooter in low-light and dynamic circumstances.
The defense contended that if Guevarra could accurately recognize Papasin at close proximity (5 meters) due to their acquaintance, he would not have mistaken Salazar for Papasin, implying that the fatal shot might have come from a different source.

Appellant Guevarra attacked the admission of his extra-judicial confession (Exhibit A), alleging that it was not made voluntarily but under the influence of promises and supposed threats by Sgt. De la Rosa.
The defense argued that circumstances surrounding the confession—particularly issues of potential coercion and promises of leniency—rendered it suspect.

The third issue raised by the appellant centers on whether the prosecution sufficiently established his guilt beyond a reasonable doubt.
This point involves analyzing the sequence of events, corroborative testimonies, and the physical evidence (such as the positioning, injury details, and the recovered firearm) to determine if the prosecution’s case adequately linked Guevarra to the murder.