G.R. No. 67803-04 - People vs. Madali

The case involves husband and wife Patrolman Ricarte Madali and Annie Mortel Madali who, as police officers, were charged and subsequently convicted for multiple killings and injuries.
The criminal acts arose from an altercation between members of the Gasang family—specifically, between Felix Gasang (aged twenty) and an associate of Ramon, the Madali spouses’ son.
Initial confrontation occurred on October 26, 1979, when Felix was involved in a fistfight with a friend of Ramon. A subsequent intercession resulted in Felix being mauled with a “chako” (a sharp cutting weapon).

The following day, during a summons at the municipal building, Patrolman Ricarte Madali reportedly scolded Felix and his companion Arnaldo Fadriquilan, threatening they would be jailed.
Madali made verbally aggressive and menacing statements—including threatening to “sow bullets” in Felix’s body—which set the tone for the violent events that followed.
Accompanied by his father-in-law, Agustin Mortel, Madali’s rhetoric escalated the situation, suggesting that extreme measures were warranted against Felix and his companions.

Around 9:00 p.m., Felix Gasang and his cousin Agustin Reloj were returning home in sitio Marawi, San Agustin, Romblon.
After parting ways, incidents unfolded near Madali’s residence:

Ricarte Madali encountered Agustin Reloj approximately fifteen meters from his house, accusing him of having helped in fighting his son.
Madali dragged Reloj toward his house; during the scuffle, Annie Madali intervened by clubbing Reloj with a piece of wood.
Amid the struggle and attempts of Agustin Reloj to escape, Madali fired his .38-caliber service revolver, striking Reloj below the right hip.

As Reloj fled, Felix Gasang appeared and was identified by Annie’s flashlight; following a brief exchange and unsuccessful attempts at de-escalation, Madali shot Felix twice.
Cipriano Gasang, father of Felix and brother of the deceased, arrived at the scene and was also shot by Madali, while his daughter Merlinda sustained a gunshot wound.

Eyewitness accounts from victims Agustin Reloj and Merlinda Gasang detailed the rapid succession of events including the utterance of warnings by both Madali and Annie.
Autopsy findings confirmed that Felix and Cipriano died from hemorrhages due to gunshot wounds, with detailed bullet trajectories provided.
Merlinda’s injury in the leg incapacitated her for ten to fifteen days while requiring prolonged hospital treatment.
Agustin Reloj’s wound to his right thigh resulted in a brief incapacitation and minor medical expense.

Madali voluntarily surrendered to the authorities, handing over his service revolver, which was later examined showing two remaining bullets.
Two informations were subsequently filed (Criminal Cases Nos. 981 and 982), charging the couple with multiple murder, frustrated murder, and the complex crime of murder and frustrated murder.
At trial:

Both defendants testified in their own defense, with Madali asserting that an intruder attack, marked by stoning of their residence, precipitated the violent encounter.
Annie contended that her involvement was limited to observations and attempts at warning her husband.
The prosecution presented eyewitness testimonies from surviving victims (Agustin Reloj and Merlinda Gasang) as well as documentary and forensic evidence.

Court records were compromised when the Romblon capitol building was razed, necessitating the reconstitution of the case files.
A key prosecution witness, Roman Galicia, recanted his testimony, thus raising issues regarding witness credibility.
Only the testimony of Ricarte Madali, amongst the defense’s accounts, was comprehensively heard by the trial court.

Whether the testimonies of the surviving victims, Agustin Reloj and Merlinda Gasang, were sufficiently corroborated to establish the chain of events.
The weight and reliability of the recanted testimony of Roman Galicia and conflicting statements by police witnesses Morales and Galang.

Whether the acts committed by Ricarte Madali and Annie Mortel Madali should be classified as murder, frustrated murder, or as a complex crime combining elements of both.
Whether the single bullet that injured both Cipriano Gasang and Merlinda Gasang warrants a charge for the complex crime of murder and frustrated murder.

Whether Ricarte Madali’s actions could be justified as acts of self-defense given the alleged prior attack (stoning) on the Madali residence.
The sufficiency and credibility of the defense’s assertion that the incident arose from an unprovoked attack that placed the defendant’s life in danger.

The extent of Annie Mortel Madali’s participation in the commission of the crimes:

Whether her acts (beaming a flashlight, uttering inciting words, and physically striking during the altercation) constituted direct participation or amounted merely to accomplice liability.

Whether there was sufficient evidence to prove a conspiracy or joint criminal design between the Madali spouses.

The impact of Ricarte Madali’s voluntary surrender on the imposition of the appropriate penalty.
Whether the mitigating circumstances should affect the compensation for hospitalization and medical expenses as well as the degree of criminal liability.