G.R. No. L-35465 - People vs. Karunsiang Guiapar

The case was filed as Criminal Case No. 40 in the CFI of Cotabato City on August 26, 1970, charging Karunsiang Guiapar and Sapal Dadas with robbery with homicide.
The information alleged that on or about June 3, 1969, in Nuling (now Sultan Kudarat), Cotabato, the accused, in concert with a co-conspirator (Karim Abo, who remained at large), committed robbery by forcibly taking a revolver and cash belonging to Patrolman Demetrio Fernandez.
During the commission of the robbery, the accused—armed with a hard wood piece and a hunting knife—assaulted the victim, leading to several stab wounds which directly caused his death.

Upon arraignment on October 26, 1970, both accused pleaded not guilty.
On January 5, 1971, the prosecution presented initial witnesses: Dr. Rogelio Chua, the attending physician of the deceased, and Patrolman Rakman Tomas.
On March 17, 1971, co-accused Sapal Dadas manifested an intention to change his plea.

Following the appraisement of the consequences by his counsel, Dadas was re-arraigned and pleaded guilty to the charged crime.
With the trial court’s consent and the People’s approval, Dadas was allowed to testify for the defense wherein he exculpated Karunsiang Guiapar from participation in the crime.

Kasan Lampak, an inmate present in the jail cell during the incident, testified as an eyewitness.
His account detailed that on the morning of June 3, 1969, at around 5:00 a.m., the prisoners were allowed out by Patrolman Demetrio Fernandez to attend to personal needs.
As soon as the cell door was opened, the accused allegedly struck the guard with a piece of wood at the left occipital region; meanwhile, Sapal Dadas stabbed the guard with his own knife and Karim Abo kicked him.
Additional details included the fact that the weapon (the piece of wood) had been brought into the cell the night before by Guiapar and that prior plans to escape or even invite other inmates were discussed.

Patrolman Rakman Tomas and Patrolman Marumpil Lilang presented testimony regarding the discovery of the wounded guard, the missing revolver, and wallet containing P70.00.
The guard’s death following an emergency operation and the recovery of stolen items were established through their statements.

Guiapar testified regarding the events, asserting that he played no active role in the killing and that it was instead the doing of a co-escaped individual (Karim Abo).
His account sought to distance himself from the direct acts of violence, emphasizing a claim of coercion and a forced escape due to threats by Karim Abo.

On March 31, 1971, the trial court found Karunsiang Guiapar guilty as co-principal of robbery with homicide, basing its decision on the collective testimonies (especially that of Kasan Lampak and the admissions contained in Sapal Dadas’s testimony).
Guiapar was sentenced to death with qualifying circumstances of treachery, evident premeditation, abuse of superior strength, and craft by befriending the victim.

In view of Guiapar’s youth (claiming to be 25 years old) and susceptibility to reform, the court recommended the commutation of the death penalty to life imprisonment.

Additional penalties imposed included indemnifying the heirs of Demetrio Fernandez and payments for the stolen property.

Guiapar appealed his conviction, arguing that the trial court erred in convicting him on the sole strength of his co-accused’s testimony.
The appellate review scrutinized the reliability of the co-accused’s testimony and the sequence of events, including inconsistencies about who struck the guard with the piece of wood.
The appellate court, however, found that the evidences, taken in their entirety and in light of corroborating eyewitness testimony, sufficiently established Guiapar’s participation as a co-conspirator in the robbery with homicide.

Whether the testimony of co-accused Sapal Dadas, who had pleaded guilty and sought to absolve Guiapar, was sufficient and reliable to exonerate him from direct participation in the crime.
The court’s handling of potentially conflicting testimonies regarding the precise actions of the accused during the commission of the crime (specifically, whether Guiapar or Karim Abo struck the victim with the piece of wood).

Whether Guiapar, by being a party to the escape and robbery, can be held liable for homicide even if his direct participation in killing appears minimal or ambiguous.
The legal implications and principled limitations of convicting him based on the theory of co-conspiracy and direct participation in the illegal act.

The extent to which factors such as treachery, evident premeditation, abuse of superior strength, and craft were demonstrated by the evidence, and whether all these should justly justify the imposition of a death sentence or reclusion perpetua.
The legal relevance of the victim’s act of befriending and the normal practice of opening prison cells in interpreting the alleged acts of abuse of superior strength and premeditation.

Whether the conviction and sentencing of Guiapar, especially in light of the possibility of testimonial errors and the involvement of an absent co-accused (Karim Abo), compromised his constitutional rights to be present at trial, to confront accusers, and to have full defense representation.