Case Digest (G.R. No. 158189)
Facts:
Eustaquio Manalo y Rebollos was charged with the murder of Victor Saavedra before the Court of First Instance of Zamboanga City, which cited the events occurring on or about September 15, 1973. On that date, Victor Saavedra, accompanied by his wife Julia Tolentino Saavedra and two children, was evacuating due to escalating violence in their neighborhood in Buug Mundo, Vitali District, Zamboanga City. They were traversing a trail with Victor riding a carabao pulling a sled loaded with family belongings, followed by his son Bernardito, who rode a cow also pulling a sled. Julia and Felizardo were situated behind them.As Victor crossed the Buug Mundo creek, Julia heard gunshots and saw Victor fall off the carabao. In a state of panic, Julia and Bernardito sought refuge among the bushes. They observed Eustaquio Manalo approach Victor’s fallen body carrying a shotgun, after which he allegedly rummaged through Victor’s belongings. Following the incident, Julia reported her husband&#
Case Digest (G.R. No. 158189)
Facts:
- Incident and Charges
- The accused, Eustaquio Manalo y Rebollos, was charged with murder before the Court of First Instance of Zamboanga City.
- The charge specified that on or about September 15, 1973, in Zamboanga City, armed with a shotgun, the accused committed murder against Victor Saavedra by wilfully, unlawfully, and feloniously shooting him with evident premeditation and treachery.
- Description of the Crime
- According to the People’s version:
- At around 4:00 p.m., the deceased Victor Saavedra, his wife Julia Tolentino Saavedra, and their two children were en route to Sibulao, Zamboanga City, to evacuate due to a deteriorating peace and order situation.
- Victor was riding a carabao pulling a sled loaded with seven heads of chicken, a can of petroleum, and other belongings; he was accompanied by his son Bernardito and his wife, with additional details on the mode of transport.
- After crossing the Buug Mundo creek, before his companions could reach the water, a gunshot was heard:
- Both Julia and Bernardito heard the shot, and soon after, they observed Victor Saavedra falling from the carabao.
- A second gunshot ensued before Julia and her children could reach the fallen victim, prompting them to hide in the nearby bushes.
- Witness Testimonies and Evidence at the Scene
- Eyewitness Accounts
- Julia Tolentino de Saavedra, the widow, testified that after the shots, she and her children saw the accused emerging from the bushes with a shotgun slung on his shoulder.
- Bernardito Saavedra echoed his mother’s account regarding the hearing of the shots.
- Additional Testimonies
- Jose Ventura, a barangay captain then also acting as a barrio councilman, testified that he and the accused were attending a conference at the time when Leonora Saavedra (Victor’s sister) sought help reporting the incident.
- Pat. Magdaleno M. Alvarez of the Zamboanga City Police corroborated aspects of the incident, particularly regarding the scene and location of the body.
- Medical and Forensic Evidence
- The body of Victor Saavedra was recovered the following day and subjected to a medico-legal examination by Dr. Rogelio Silapan.
- The post-mortem report revealed multiple gunshot wounds:
- Two wounds in the submandibular and infra-auricular regions.
- Three wounds located between the intercostal spaces of the left chest.
- A gunshot wound at the deltoid muscle directing toward the scapular region.
- The cause of death was attributed to shock and hemothorax secondary to the multiple bullet wounds.
- Additional Circumstances
- The widow incurred funeral expenses and embalming costs.
- The accused did not testify on his own behalf; instead, testimony against him was provided by eyewitnesses as well as corroborative evidence from attending police officials.
- Criminal Proceedings and Trial Court Findings
- Judge Alberto V. Seneris of the Court of First Instance found the accused guilty beyond reasonable doubt as a result of:
- The positive identification of the accused by eyewitnesses.
- The clear sequence of events established through medical, forensic, and testimonial evidence.
- The trial court sentenced Eustaquio Manalo y Rebollos to reclusion perpetua, imposed additional accessory penalties, and ordered indemnity lowered to P12,000.00 (later modified upon appeal).
- Defense Arguments and Inconsistencies Highlighted
- The accused’s defense centered on an alibi, relying mainly on Jose Ventura’s testimony which indicated that he and the accused were at a conference during the time of the crime.
- The defense argued inconsistencies in the prosecution witnesses’ testimonies:
- Discrepancies regarding whether the accused was seen with a shotgun slung on his shoulders.
- Contradictory statements concerning the exact words used by Julia Saavedra when initially reporting the incident.
- Conflicting reports regarding whether the witnesses actually saw the accused firing the weapon.
- The defense also raised the issue of a lack of apparent motive given the preexisting friendly relationship between the accused and the deceased.
Issues:
- Identity and Presence of the Accused at the Scene
- Whether the accused, Eustaquio Manalo y Rebollos was physically present at the scene at the time the crime was committed.
- Whether the eyewitness identification conclusively established his participation in the murder.
- Credibility and Consistency of Testimonies
- The reliability and consistency of the eyewitness testimonies provided by Julia Tolentino de Saavedra and Bernardito Saavedra.
- The impact of the discrepancies raised by the defense regarding the details of the testimony, such as the description of the accused and the sequence of events.
- Evaluation of the Alibi Defense
- Whether the alibi provided by the defense, based on Jose Ventura’s testimony of attending a conference, sufficiently exonerates the accused.
- The need for a conclusive and clearly established alibi that leaves no room for doubt.
- Relevance of Motive in the Absence of Multiple Suspects
- The significance of motive in cases where the identity of the culprit is clearly established by eyewitness and forensic evidence.
- Whether the alleged friendly relationship between the accused and the deceased could discount the likelihood of murder.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)