G.R. No. 93055-56 - People vs. Mancio y Salveron

The People of the Philippines charged five accused-appellants with heinous crimes—murder and attempted murder.
The accused-appellants are Roldan Mancio y Salveron, Rolando C. Yero, Edgar David, Borong Estrera, and Richard Doe.
The case involves the death of Certified Public Accountant Andrew Angelo and serious injuries sustained by Erolando Toledo.

On the evening of February 12, 1983, a group including A. Angelo, E. Toledo, and three others attended a party at Kanlaon Construction in Bagong Silang, Caloocan City.
After the party, the group reconvened to fetch A. Angelo from his home at approximately 12:15 A.M., February 13, 1983, upon his mother's call.
Later, A. Angelo, feeling restless, decided to go out once more accompanied only by Erolando Toledo and Jonifer Tadungog.

As A. Angelo and his companions walked along an alley, they encountered a group of five men who had been sitting on the sidewalk.
The confrontation began when A. Angelo recognized one of the attackers, prompting a greeting that led to the immediate escalation of violence.
Accused-appellant Roldan Mancio acknowledged A. Angelo, which precipitated the ensuing attack.

Roldan Mancio immediately stabbed A. Angelo with a long knife while holding him by the nape, intensifying the stabbing with a deep, forceful thrust.
During the melee, Rolando Yero hacked Erolando Toledo on the left side of his face with a 2-1/2 foot long bolo, while also participating in the assault against A. Angelo by hacking him on the head.
Other assailants contributed:

Richard Doe was implicated in raising the head of the felled A. Angelo by pulling his hair.
Rorong Estrera slashed A. Angelo’s throat with a balisong.
Edgar David struck A. Angelo forcefully on the back with a lead pipe.

Erolando Toledo received immediate treatment for a three-inch laceration on his left cheek at the Jose Reyes Memorial Hospital.
A. Angelo was initially brought to Paulino Hospital, later transferred first to Legaspi Hospital, and finally to Quezon City General Hospital for several operations.
Before succumbing to his injuries on February 16, 1983, A. Angelo made a dying declaration, confessing and identifying his attackers.

Accused-appellant Roldan Mancio presented a medical slip from Quezon City General Hospital, claiming he had sustained injuries from a nearby rumble.
Accused-appellant Rolando Yero maintained that he was asleep with his family at the time of the crime.
Both defenses failed to substantiate that it was physically impossible for them to be present at the scene, given the proximity of their residences to the location of the crime.

Nine prosecution witnesses corroborated each other, offering a detailed and consistent narrative of the events.
Eyewitnesses provided clear and positive identifications of the accused during the violent onslaught.
The dying declaration of A. Angelo, recorded shortly before his death, further sealed the credibility of the prosecution’s case.
The trial court gave significant weight to the witnesses’ accounts and the physical evidence, leading to the conviction of the accused-appellants.

Whether the trial court committed error in giving greater credence to the prosecution’s eyewitness testimonies over the defense’s conflicting accounts.
The extent to which the trial court’s factual findings regarding witness credibility were supportable under the evidence.

Whether the submitted alibis (a medical slip for Mancio and the claim of being asleep for Yero) were adequate to establish that it was physically impossible for the accused to be at the scene.
The effect of the geographic proximity of the accused’s residences to the site of the crime in undermining their alibi defenses.

Whether the totality of the evidence presented by the prosecution reached the threshold of proof required to convict the accused beyond reasonable doubt.
Whether the trial court erred in convicting the accused-appellants despite the defense’s objections pertaining to evidentiary insufficiency.