G.R. No. 140514-15 - People vs. Ignas

Appellant June Ignas y Sanggino, an elementary school graduate who resided in Cruz, La Trinidad, Benguet, operated a bakery in his hometown.
He was married to Wilma Grace Ignas, with whom he had a minor child.
Wilma Grace previously worked as a cashier for Windfield Enterprise, owned by Pauline Gumpic, whose brother was Nemesio Lopate.

In September 1995, Wilma Grace confided to her close friend Romenda Foyagao that she was having an affair with Nemesio Lopate.
On the evening of October 16, 1995, Wilma Grace, Romenda, and Nemesio traveled to Manila, where Wilma Grace lodged with Nemesio at the Dangwa Inn before departing for Taiwan on October 18, 1995.
Subsequent letters written by Wilma Grace—addressed to Romenda but partly intended for Nemesio—requested that Romenda inform June Ignas about the affair.
Late in February 1996, Romenda disclosed the extramarital affair and details of their encounter in Manila to appellant.

Shocked and enraged by the revelation, appellant declared his intent to kill Nemesio Lopate.
He gathered all the incriminating letters from Romenda, which further fueled his anger.
Prior to the killing, a discussion with his neighbor and tribal elder Alfred Mayamnes confirmed local gossip regarding the affair, and the matter soon became of communal concern.

On March 10, 1996, at around 10:00 p.m. at the Trading Post in La Trinidad, Benguet, multiple witnesses observed events during which the fatal shooting occurred.

Prosecution witness Annie Bayanes, a vegetable trader, witnessed two gunshots and saw a man (later identified as appellant) tucking a handgun into his waistband immediately after a victim fell.
Witness Marlon Manis, a close neighbor of appellant, saw from a distance a person with a build and gait similar to that of appellant departing from the scene.
At about 10:30 p.m., witness Mona Barredo, a former coworker of appellant, testified that he visited her residence, removed spent cartridges from his jacket, instructed her to dispose of them, and admitted killing his wife’s paramour.

Dr. Doris C. Jovellanos, the Municipal Health Officer, noted multiple entry wounds on the body of Nemesio Lopate, consistent with a gunshot fired at close range (less than three feet).
A bullet was recovered from the victim’s left shoulder and spent gun shells were collected from the vicinity, including from the garden near Barredo’s house.

Appellant claimed an alibi based on a business arrangement with fellow baker Ben Anoma in Kayapa, Nueva Vizcaya, claiming that since March 8, 1996, he had been operating in Kayapa, which is approximately 79 kilometers away from La Trinidad.
Defense witness Ben Anoma corroborated appellant’s claim that they had commenced baking together in Kayapa and remained there until police brought appellant in for questioning on March 14, 1996.
Despite the alibi claim, multiple testimonies and circumstantial evidence placed appellant at or near the scene of the killing on the night in question.

A conversation with friend Julio Bayacsan at the police station revealed his admission of having shot Nemesio Lopate.
Pauline Gumpic, the victim’s sister, similarly testified that appellant admitted to killing her brother due to the affair with his wife.
SPO4 Arthur Bomagao testified that appellant voluntarily admitted to using a .38 caliber handgun in the killing.

The collection and presentation of physical evidence (spent cartridges, ballistic findings) along with the circumstantial testimonies reinforced the narrative of his culpability.

Whether the evidence established that appellant committed murder or, as the amended information suggested, only homicidal (unlawful killing) conduct.
The significance that the amended information did not specifically allege qualifying circumstances such as treachery, evident premeditation, and nocturnity.

The reliability and admissibility of the circumstantial evidence—particularly the identification testimonies of Annie Bayanes and Marlon Manis.
Whether the delay and potential inconsistencies in the testimonies of prosecution witnesses (including Pauline Gumpic, Bayanes, Bayacsan, and Mona Barredo) undermined the chain of evidence.

Whether appellant’s alibi (his presence in Kayapa with his business partner) was credible given the distance and time constraints between Kayapa and La Trinidad.
Whether the circumstantial evidence effectively negated the possibility of his presence elsewhere during the crime.

Whether the special aggravating circumstance of using an unlicensed firearm was properly established by the prosecution with sufficient evidence.
Whether mitigating circumstances, such as immediate vindication of a grave offense, passion and obfuscation, or voluntary surrender, were applicable or properly considered.

Whether the award for actual damages (funeral expenses) and loss of earning capacity was supported by competent proof.
Whether the amounts awarded were excessive or unconscionable in light of the evidence provided (e.g., actual receipts supporting only part of the claimed losses).