Case Digest (G.R. No. L-32733)
Case Digest (G.R. No. L-32733)
Facts:
People of the Philippines v. Alfonso Manangan, G.R. No. L-32733, September 11, 1974, Supreme Court Second Division, Aquino, J., writing for the Court.The prosecution charged Alfonso Manangan (appellant) with the murder of Alejo Cayago. At about 1:00 a.m. on November 13, 1968, Alejo Cayago was shot five times while urinating on the open porch (batalan) of his house in Barrio Vedania, Mangatarem, Pangasinan, and died instantly. His wife, Rosalina Garlitos (Cayago), awakened by the noise, shone a three-battery flashlight and saw a man she identified as appellant—whom she had known for years and who was her compadre—standing about four meters away wearing a distinctive fur-like black hat and armed with a carbine; the man fired at her, grazing her leg. She shouted for help and the assailant and four companions fled.
Local officials and the municipal health officer inspected the scene later that morning. Doctor Raymundo Velasquez found five entrance and five exit wounds and opined death occurred at about 1:00 a.m.; the trajectory indicated the shooter was below the victim. The chief of police sketched the scene and recovered eight empty shells, which, by location, corroborated Rosalina’s account about the shooter’s position. Rosalina executed an affidavit identifying Manangan on November 15, 1968; a neighbor, Lydia de Guzman, executed an affidavit stating animosity between Cayago and Manangan. The alleged motive was resentment by Manangan over Cayago’s report that Manangan had stolen a fishing net.
Manangan was later arrested and an information for murder was filed April 22, 1969. At trial he asserted an alibi that he resided in San Clemente, Tarlac, since 1966 (or 1967–1968 as witnesses varied) and was seen there around midnight on the night in question. The trial court disbelieved his alibi, gave greater credence to the testimony of local officials and to circumstances permitting rapid travel between the two towns, and convicted him of murder, sentencing him to reclusion perpetua and ordering indemnity of ₱12,000. Manangan appealed to the Supreme Court, contesting (1) reliance on the uncorroborated testimony of the widow, (2) the trial court’s alleged reliance on an alleged unsigned list found in a river, and (3) the finding of evident premeditation.
Issues:
- Was conviction proper based on the testimony of the victim’s wife and the attendant circumstantial evidence?
- Should probative value be given to the alleged unsigned list of persons to be assassinated allegedly found in the Ladiawan River?
- Was the killing attended by evident premeditation as an aggravating circumstance?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)