G.R. No. 146710-15 - Estrada vs. Desierto

Fernando Iligan and Edmundo Asis, uncle and nephew respectively, were charged with murder and convicted by the Court of First Instance of Camarines Norte, Branch II. Juan Macandog, the third accused, was at large and never apprehended.
The accused appealed the decision, with Fernando Iligan and Edmundo Asis seeking reversal of their conviction and the penalties imposed.

On or about 3:00 a.m., August 4, 1980, at sitio Lico II, barangay Sto. Domingo, Vinzons, Camarines Norte, the accused, conspiring together, attacked Esmeraldo Quinones, Jr. using a bolo (sinampalok).
Iligan wielded the bolo and hacked Quinones, Jr. on the forehead, causing fatal injuries that resulted in the victim's death.
The incident occurred on a public highway; prior to the fatal attack, a confrontation took place involving Quinones, Jr. and his companions and the accused.

At around 2:00 a.m., Esmeraldo Quinones, Jr. and companions Zaldy Asis and Felix Lukban were walking home from a fiesta dance when they encountered Iligan, Edmundo Asis, and Macandog.
Edmundo pushed the group aside, provoking Zaldy to box him; a brief altercation ensued but the three companions tried to avoid a fight.
Iligan drew his bolo and attacked Zaldy but missed; the trio fled and eventually stopped near Quinones, Jr.’s house to rest, inviting the companions to accompany him there.
While walking to the house, the accused suddenly appeared and Iligan hacked Quinones, Jr. on the forehead, causing him to fall.
Witnesses fled but later returned upon hearing shouts; they found Quinones, Jr. dead with severe head injuries.
The victim's body was autopsied on the same day by Dr. Marcelito Abas.

The victim, aged 21, sustained multiple fractures on the entire left half of the head and massive cerebral hemorrhage.
There was also an incised wound on the right eyebrow, abrasions on the left shoulder and right side of the neck.
The death certificate cited "shock and massive cerebral hemorrhages due to a vehicular accident" as cause of death.

The accused denied the charges and claimed to be at home during the incident.
Fernando Iligan testified he had left his house around midnight to fetch visitors. He met Edmundo, who appeared drunk, and invited him to the dance hall.
They did not reach the dance hall due to Edmundo being boxed by an unidentified person; Iligan escorted Edmundo home, accompanied by Juliano Mendoza.
Iligan and Mendoza then proceeded home, arriving between 1:30 and 2:00 a.m.
Edmundo corroborated Iligan’s testimony and claimed he woke up the next morning at 7:00 a.m.

The trial court did not credit the death certificate’s vehicular accident cause on grounds that the accident was not established.
Testimony of the victim’s father indicated that the accident could not have caused the superficially visible wounds.
Photographic evidence showed head injuries consistent with hacking rather than crushing by a vehicle tire.

The court found conspiracy between Iligan, Edmundo Asis, and Macandog to kill Quinones, Jr. or his companions to avenge Edmundo’s boxing incident.
Aggravating circumstances of treachery and evident premeditation were ascribed to the accused.
Iligan and Edmundo were convicted of murder and sentenced to reclusion perpetua, with financial indemnity to the victim’s heirs.

The defense emphasized the possibility that Quinones, Jr.’s death was due to vehicular accident citing autopsy findings and Dr. Abas' testimony.
Prosecution witnesses noted tire marks at the scene and brain matter scattered on the road, supporting the vehicle accident theory.
The victim’s father testified that he saw Iligan holding a bolo while chasing the group.
Defense questioned the sufficiency and credibility of evidence supporting conspiracy and aggravating circumstances.

Whether Fernando Iligan and Edmundo Asis were properly convicted of murder.
Whether the cause of death was murder or a vehicular accident.
Whether the aggravating circumstances of treachery and evident premeditation were correctly appreciated.
Whether Edmundo Asis was rightly held liable as co-conspirator and co-principal.
Whether the monetary award for unrealized income of the victim was justified.