A.M. No. 2440-CFI - Iglesia Ni Cristo vs. Gironella

A group of accused, including the Manero brothers (Norberto, Jr., Edilberto, Elpidio), along with co-accused such as Severino Lines, Rudy Lines, Efren Plenago, Roger Bedano, and others, convened inside an eatery at Km. 125, La Esperanza, Tulunan, Cotabato on the morning of 11 April 1985.
During the meeting, they discussed plans to liquidate suspected communist sympathizers.
Conspiratorial ideas were noted on a cigarette wrapper and later publicized on placards nailed and posted near the eatery, indicating a list of intended victims.
The conspirators agreed that if the primary target, an Italian priest known as Fr. Peter Geremias, could not be killed, another Italian priest (later identified as Fr. Tulio Favali) would be substituted.

Later in the morning, after the planning stage at the restaurant, the accused proceeded with the plot by moving from the initial meeting spot to other locations in the vicinity.
At about 4:00 PM, the group, armed and organized, went to the residence of Rufino Robles (also identified as Bantil) where an altercation ensued.

Edilberto Manero fired at Bantil, injuring him in the process.
Despite the injuries, Bantil managed to seek refuge; however, the group ordered confinement of the area to ensure no escape or timely assistance.

The accused, already positioned in the scene, intercepted the priest.
Norberto, Jr. and Edilberto Manero not only participated in the shooting but also engaged in further acts of cruelty after the fatal shots, such as taunting and desecrating the body.
Graphic details include the dismemberment of the victim’s head and the display of his brain fragments as a deliberate act of mockery and intimidation.

Concurrently, other charges were pursued for the arson of the priest’s motorcycle and the attempted murder of Rufino Robles, evidencing a multi-faceted execution of the criminal plan.

The case was consolidated under three counts: Murder (Fr. Favali), Attempted Murder (Rufino Robles), and Arson (burning of the motorcycle).
The trial court found the accused guilty beyond reasonable doubt on all counts.

The accused were sentenced to reclusion perpetua (for murder) and indeterminate penalties (for attempted murder and arson) in accordance with the applicable provisions of the Revised Penal Code and the Indeterminate Sentence Law.
Monetary awards were imposed including a civil indemnity (later modified), attorneys’ fees, court appearance fees, and exemplary (and moral damages, although later deleted) in relation to the offenses.

Appellants Severino Lines, Rudy Lines, Efren Plenago, and Roger Bedano challenged the conviction on the ground of their alibi defenses.

The accused-appellants contended that they were at other locations at the time of the commission of the crimes.

Claims included being engaged in agricultural work or running errands far from the scene.

Eyewitness testimony from individuals present at the eatery and near the crime scene consistently placed the accused-appellants at the locus criminis.

Testimony revealed that the accused were present from as early as 10:00 AM until well after the afternoon shooting events.

The available evidence demonstrated not only their physical presence but also their participation in the conspiracy and subsequent acts to ensure the execution of the criminal plan.

Whether the accused-appellants’ alibi claims — asserting that they were elsewhere — are sufficient to establish physical impossibility of their presence at the crime scene.
How the proximity of their alleged locations to the locus criminis affects the viability of their alibi.

Whether mere presence at the site and participation in planning or subsequent actions suffices for establishing complicity in the crimes.
Whether the principle that "the act of one is the act of all" in a conspiracy adequately imputes criminal liability on all co-conspirators, regardless of who delivered the fatal shot.

Whether the award of moral damages to a juridical person (and to the heirs) is proper, given the legal principles governing such awards.
The propriety of modifying the amount of the civil indemnity awarded to the victim’s family.