G.R. No. 116600 - People vs. Manlusoc

On January 8, 1991, at approximately 9:30 p.m. in Calapan, Oriental Mindoro, four members of the Philippine National Police (PNP) ambushed and fatally shot Isagani Mazon.
The victim sustained a total of 21 gunshot wounds, several of which were fired at his back, evidencing a deliberate and ruthless attack.
The manner of the killing—synchronized shooting by the accused—resulted in the immediate death of Mazon and demonstrated characteristics of a premeditated attack.

Instead of being incarcerated in the customary provincial jail, the accused were initially detained by their superiors in the PNP Stockade because of their status as law enforcement personnel.
Soon after, the accused exploited or were allowed by apparent negligence to leave their designated confinement, leading to their subsequent escape or absence from scheduled hearings; only one was re-arrested soon afterward.
Despite the pending criminal charges, the accused filed motions for bail and for transferring their detention from the provincial jail to the PNP Stockade, resulting in multiple hearings beginning in October 1991 through to early 1992.

Eyewitness testimonies from individuals such as Lilian Francisco and Herman Mejico, Jr. who observed the sequence of events during the shooting.
Documentary evidence comprising reports, affidavits, and forensic exhibits (e.g., the Necropsy Report, rough sketch of the crime scene, and Certificate of Death) prepared by Dr. Arturo Alberto, the medico-legal expert.

The defense’s evidence was limited and largely procedural after the accused failed to produce their own witnesses or further evidence due to repeated escapes and non-appearance at hearings.
The prosecution also introduced documents related to previous arrest warrants and other ancillary evidence to establish the continuous criminal behavior of the accused.

The trial court allowed the accused to be detained in a PNP facility rather than a secured jail, facilitating their eventual escape.
Multiple law enforcement officials — including the PNP Provincial Director, the Jail Warden, and even the Provincial Governor — were implicated for their negligence or inaction in preventing the escape and for not strictly enforcing court orders.

These lapses contributed to an environment where the accused could roam freely at times, thereby complicating the scheduling of hearings and the presentation of evidence.

The trial court held several hearings (from November 1991 into mid-1992) to resolve the issues raised in the petition for bail and to receive the evidence on the merits.
After repeated postponements and noting the accused’s continual escape (which the court considered as a waiver of their right to present evidence), the trial court proceeded with the promulgation of judgment on July 1, 1992.
The trial court found all the accused guilty beyond reasonable doubt as principals in the crime of murder, attributing the killing to the use of treachery and the presence of aggravating circumstances such as the commission of the offense by a band and advantage of superior strength.
The sentence imposed was reclusion perpetua, with the additional order to pay P50,000.00 as actual and compensatory damages to the heirs of the victim.

Accused (notably Eric Manlusoc, whose appeal was eventually the only valid appeal) raised seventeen distinct errors concerning the sufficiency of the findings, the application of the aggravating circumstances, evidentiary issues regarding the fatal shot, and the credibility of the prosecution witnesses.
Among these issues were claims that the trial court failed to provide clear findings of fact as mandated by the Constitution, that the evidence failed to establish the essential elements of murder (including treachery), and that the accused’s escape should have influenced a different outcome.
The appellate court and subsequently the Supreme Court reviewed the allegations, and while various procedural and evidentiary concerns were noted, none were deemed sufficient to reverse the trial court’s findings or the conviction.

Whether the trial court provided adequate findings of fact to support the conviction of murder in conformity with the requirements of the Constitution and the Rules of Court.
Whether the conduct of the trial court and law enforcement authorities—particularly in allowing the accused to be detained in a less secure facility and subsequently escape—compromised the fairness of the proceedings.

Whether the evidence, including the eyewitness testimonies and forensic documents, demonstrated beyond reasonable doubt that the accused committed murder.
Whether the application of the aggravating circumstance of treachery, as well as the factors of band and abuse of superior strength (the latter being absorbed by treachery), was correct in light of the evidence.

Whether the accused’s escape during trial, and their failure to present further evidence or testify, should be considered an admission of guilt or a factor necessitating a revision of the conviction.

Whether the inconsistencies or criticisms raised against the prosecution witnesses (notably Lilian Francisco and Herman Mejico, Jr.) were sufficient to undermine the chain of evidence against the accused.

Whether the principle that the act of one conspirator is imputed to all was appropriately applied, given the coordinated nature of the crime and the evidence of concerted action.