G.R. No. L-6585 - People vs. Libria

This case involves the killing of Jaime Idloy during events held in the barrio of Buri, municipality of Alang-alang, Leyte.
Pedro Libria, an ex-soldier of the Philippine Scouts, and Esteban Campo were originally accused in connection with the murder.
Prior to trial, Esteban Campo was discharged from the information but later testified as a witness for the Government.

During the fiesta and a game of monte, tensions arose when Jaime Idloy, who was known to be a bully, confronted partygoers.
Idloy boxed Esteban Campo after a dispute regarding Tong collections, indicating a physical altercation during the fiesta.
Later that evening, during a dance, Idloy also boxed Pedro Libria, further escalating the personal animosity toward him.

Approximately two weeks after the initial altercations, specifically on the evening of June 12, 1950, Libria, armed with a carbine, went to Campo’s residence in the barrio of Buri.
At Campo’s home, his wife Teofila Resano and Campo himself received Libria.
Libria invited Campo to accompany him in searching for Idloy, ostensibly to settle their differences by avenging past wrongs, although Campo testified that he went partly out of fear.
In the barrio of Lingayon, Libria located Idloy in the house of Paulino Verzosa, lying on a bench.
The methodical execution:

Libria and Campo positioned themselves strategically—Campo hiding behind a coconut tree and Libria taking cover in a banana grove.
As Idloy began to step away from the bench, Libria fired his carbine; the first bullet struck Idloy in the arms and chest.
A second shot hit the victim in the lower trunk and fractured his sacral bone, resulting in almost instantaneous death.

The killing was noted for its precision, which was not surprising given Libria’s military background.

The shooting was witnessed by Esteban Campo, whose testimony verified the sequence of events and Libria’s active participation.
Testimony from Campo’s wife corroborated the claim that Libria had invited Campo to join him on a mission of revenge against Idloy.
Despite some doubts regarding the complete impartiality of these testimonies because of Campo’s initial involvement and moral support for the killing, the trial court and subsequently the appellate court found them persuasive in establishing the facts.

Libria denied any active participation in the murder.
He attempted to establish an alibi by asserting that on the evening of June 12, 1950, he was:

Making copra at the house of one Pedrero earlier in the day, and
Attending a drinking party at the residence of his witness, Eleuterio Brando, by 11:00 p.m.

The trial court, however, did not give credence to this alibi, finding that the evidence placed Libria at the scene of the crime.

Was the evidence, particularly the testimonies of Campo and his wife, sufficient to establish Libria’s guilt beyond reasonable doubt?
How do the circumstances surrounding the testimonies, given Campo’s potential partiality, affect their probative value?

Can Libria’s purported alibi of being engaged in other activities at the time of the murder be reconciled with the evidence placing him at the scene of the crime?
Is the alibi consistent and corroborated by reliable witnesses or evidence?

Did the facts show the presence of treachery and evident premeditation in the commission of the murder?
Should the penalty imposed be reclusion perpetua solely based on these circumstances, or does the case warrant the imposition of the death penalty as argued by the Solicitor General?

Was the alleged provocation (the boxing incident during a dance and fiesta) sufficient to invoke any measure of mitigation under the Penal Code?
Does the temporal gap between the initial provocation and the act of revenge diminish the applicability of immediate provocation as a mitigating circumstance?