G.R. No. 191723 - People vs. Las Pinas

On the early morning of May 2, 2001, at a fishpen in the Municipality of Castilla, Sorsogon, several persons were attacked in a coordinated assault.
The public prosecutor charged eight individuals with frustrated murder and murder, depending on the victim and circumstance.
Charges were filed in separate criminal cases:

Criminal Case No. 2001-5445 for frustrated murder involving the shooting of Roger Aringo (who survived due to timely medical attention).
Criminal Case Nos. 2001-5446, 2001-5447, and 2001-5448 for the killing of Edgardo, Benjamin, and Carlito, respectively, where the deaths were attributed to gunshot wounds.

According to eyewitness testimony, particularly that of Roger Aringo, the assailants arrived on a long wooden boat and entered the fishpen.
The assailants climbed a bamboo platform supported by posts, from where they suddenly opened fire on the sleeping or resting victims, catching them by surprise.
Various methods of assault were employed:

Shooting with a .38 caliber gun resulted in multiple gunshot wounds on different parts of the victims’ bodies.
In at least one instance, after incapacitating a victim, the assailants used a knife to slash the throat, and the body was thrown into the sea.

The primary eyewitness was Roger Aringo, who provided a detailed and consistent account of the events.

He described seeing specific accused individuals (Rolando Las PiAas, Merwin Las PiAas, and Jimmy Delizo) actively participate in the shooting and subsequent assault.
His testimony identified the position of the shooters and detailed the sequence in which they opened fire while either climbing or already positioned on the platform.

Family members of the deceased, such as Susan Aringo, Gleceria Lasala, and Catalino Aringo, who testified about the circumstances surrounding the assault and its aftermath.
Medical personnel, including Dr. Antonio Lopez and Dr. Salve Sapinoso, who provided testimony on the nature, severity, and cause-effect chain of the injuries sustained by the victims.
Law enforcement and investigative officers (e.g., Rowan Estrellado of the NBI, and Atty. Tomas C. Enrile) who contributed procedural evidence and witness examinations.

The defense presented its own set of witnesses attempting to establish alibis for the accused-appellants, including barangay officials and friends of the accused, asserting that they could not have been present at the fishpen at the time of the crime.

Out of the eight accused, only Rolando Las PiAas, Merwin Las PiAas, and Jimmy Delizo were apprehended and held for trial.
The cases were raffled to two separate branches of the Regional Trial Court in Sorsogon City:

RTC Branch 53 handled the frustrated murder case (Criminal Case No. 2001-5445).
RTC Branch 52 handled the three murder cases (Criminal Case Nos. 2001-5446 to 2001-5448).

Both trial courts relied heavily on the direct and detailed testimony of the eyewitness and forensic evidence to convict the accused.

The accused-appellants appealed the decisions on the grounds of alleged insufficiency of evidence, the improper application of the alibi defense, and the argument that the offense committed should be considered attempted murder rather than murder or frustrated murder.
The Court of Appeals, in its consolidated December 22, 2009 decision, affirmed the convictions of both the RTC Branches for the frustrated murder and the murder counts.
The case eventually reached the Supreme Court seeking reversal of the appellate decision, where the focus remained on the credibility of the eyewitness account, the proper evaluation of the alleged alibi, and the adequacy of the evidence to uphold the convictions.

Whether the testimony of Roger Aringo, the sole eyewitness to the incident, was sufficient to sustain convictions for both frustrated murder and the multiple counts of murder.
The evaluation of forensic and medical evidence supporting the cause-and-effect relationship between the injuries and the accused’s actions.

The court’s determination regarding the consistency and spontaneity of Roger’s testimony despite a lengthy cross-examination.
The impact of alleged inconsistencies or perceived limitations (e.g., physical inability to view the entire incident) on the probative value of the eyewitness account.

Whether the defense successfully established that it was physically impossible for the accused-appellants to have been at the scene.
The credibility of the collateral witnesses supporting the accused’s alibis compared to the affirmative eyewitness identification.

Whether the qualifying circumstance of treachery was proven in the commission of the crimes, given the method and manner of the attack.
The inference of conspiracy among the accused based on their coordinated actions before, during, and after the execution of the crime.

Whether the trial court correctly imposed the penalty ranges on the offenses—specifically, the minimum and maximum terms for frustrated murder under the guidelines of the Revised Penal Code and the Indeterminate Sentence Law.
The correctness of the awarded civil indemnities, moral, and exemplary damages given the aggravating circumstances and prevailing jurisprudence.