G.R. No. L-22366 - Guerrero vs. Court of Appeals

On or about August 29, 1978, an ambush occurred in the Municipality of Pagsanjan, Laguna, where an attack was launched against Reynaldo Baldemora and Hector Samonte.
Two criminal cases were concurrently filed:

Criminal Case No. SC-2209 charging the accused with the killing of Reynaldo Baldemora through an attack involving treachery, the use of unlicensed firearms, and an intent to kill.
Criminal Case No. SC-2210 charging the accused with having shot at Hector Samonte with similar elements, although timely medical assistance prevented his death.

The accused included Jimmy Manambit, Mauricio Llames, Ramon Mamuri, along with others (Antonio Manambit, Benjamin Lacbay, and Feliciano A. Rana) who faced varying degrees of liability.
All accused pleaded not guilty at arraignment.

Testimony of Hector Samonte describing the ambush, the sighting of four armed men (Antonio Manambit, Mauricio Llames, Benjamin Lacbay, and Jimmy Manambit) and his attempt to defend himself by grabbing a nearby gun.
Reynaldo Baldemora’s dying declaration, made on a jeepney en route to the hospital, identifying at least one of the assailants as Antonio Manambit and later suggesting additional names.
Other eyewitness accounts from police officers (Pat. Rustico Liwanag, Pat. Antonio Abillo, etc.) and bystanders detailing physical evidence such as recovered empty shells near a tamarind tree, positions of vehicles (a red car and a 70 cc. motorcycle), and location of the incident near the old municipal cemetery.
Medical evidence established that Reynaldo’s gunshot wound entered from the back and caused extensive damage to vital internal organs, while Hector’s injuries were similarly consistent with shots coming from a distance and an elevated position.

Recovery of twenty spent M-16 shells near a tamarind tree that suggested the possibility of an additional, unidentified gunman.
Items such as caliber .38 paltik and various ammunition magazines which provided context to the type of firearms used.
Photographic and schematic evidence (sketches by Patrolmen) that outlined the scene, including the position of the motorcycle, the road, and nearby structures.

The accused provided separate alibi accounts for their whereabouts at the time of the incident.

Antonio Manambit claimed he was at a house in Maytalang playing a card game, corroborated by a co-player.
Benjamin Lacbay testified he was engaged in repairing a truck at a shop in Caliraya, Laguna, with corroborative testimonies by company personnel.
Feliciano (Ochoy) Rana asserted that he was at a military detachment where he was seen by constables and other military personnel.
Mauricio Llames and Ramon Mamuri furnished alibi narratives explaining their noninvolvement, with Llames later admitting to going into hiding and surrendering only when an arrest warrant (ASSO) was issued.
Appellant Jimmy Manambit’s defense centered on his alibi that he was present at the chaplain’s quarters in Nichols Air Base, supported by the testimony of Fr. Rufino Oarga and contextual evidence regarding his family ties in the same vicinity.

After the trial court rendered its decision—with the conviction of Jimmy Manambit as principal and Llames/Mamuri as accomplices—the trial court forwarded the records for review in light of the imposed death penalty.
Deficiencies in counsel representation were noted as Jimmy Manambit’s counsel of record failed to file his brief in time, leading to the appointment of a counsel de oficio.
Appeals were filed by Jimmy Manambit (alone) and jointly by Llames and Mamuri, while dissent and arguments regarding the weight of the evidence and the treatment of alibi defenses were raised.

A longstanding family feud between the Manambits and the Samontes provided a contextual backdrop that impacted witness credibility.
Historical events, such as prior shootings and land disputes, were cited by witnesses to underline motive and bias, with multiple violent incidents already on record between the families.
The bias was particularly evident among prosecution witnesses (Hector and Zenon Samonte), whose testimonies were scrutinized for possible premeditated animosity.

Whether the reliability of the eyewitness testimonies was compromised by the deep-seated family feud.
How the discrepancies among the accounts (e.g., differing identifications and omissions) affected the establishment of a clear timeline and factual pattern.

Whether the evidence conclusively identified the accused, particularly Appellant Jimmy Manambit, as one of the participants in the ambush.
The role and impact of the “lone-unidentified gunman theory” suggested by the presence of physical evidence (spent shells) on identifying the true assailant(s).

Whether the entirety of the evidence, including physical, testimonial, and res gestae evidence, established guilt beyond reasonable doubt.
Assessment of the prosecution’s failure to reconcile conflicting testimonies and the inconsistent identification by the primary witness, Hector Samonte.

The relative weight to be given to the alibi provided by Appellant Jimmy Manambit vis-à-vis the alibi defenses of the other accused.
Whether the trial court improperly discredited Appellant Jimmy Manambit's alibi while giving credence to others, thereby affecting the outcome.

Impact of the change in trial judges on the evaluation of witness demeanor and overall credibility assessments.
Whether the appellate court should remedy possible errors resulting from the trial judge not having fully observed witness testimony firsthand.