G.R. No. L-44461 - People vs. Manuel

On January 24, 1972, thirteen members of the Alfaro family were attacked in their home in barrio Culianan, Zamboanga City.
The attack was sudden, with armed men—carrying knives and bolos—entering through a window and a loose kitchen board.
A veritable bloodbath ensued whereby five family members were killed and seven were seriously wounded.
Among those killed were Sotera, Judith, Ermida (all carrying the Alfaro surname), Margarita de los Santos, and Marilou Mendoza-Lopez.
The survivors included individuals such as Diosdado, Expedito, Ernesto, Celia, Feliciano, Jr. (who lost his left arm), Orlando, and Feliciana, with only Jeanette Alfaro remaining unscathed.

The police promptly investigated the incident, taking statements from survivors; notably, Ernesto Alfaro’s statement was taken as an “ante-mortem declaration” due to his critical condition.
Based on the forensic inquiry and subsequent investigation by the City Fiscal of Zamboanga, an information was filed charging multiple murder and multiple frustrated murder against the accused.
The accused individuals were Ceferino Manuel, Luis Eugenio, Segundino Andres (also known as “Dito”), Felipe Ramillano, Ranulfo Atilano (also styled as Felipe Atilano), and Enrique Manuel.

Luis Eugenio claimed he was engaged in threshing palay in a bodega in Balinsungay, approximately three kilometers away.
Ceferino Manuel stated he was at the house of Lt. Demaclid, some fourteen kilometers from the scene.
Segundino Andres testified that he had spent the evening at Mrs. Antonia Manuel’s house, situated just about one kilometer from the Alfaro residence.
The other accused similarly asserted that they were elsewhere, engaged in innocent pursuits.

The trial evidence included testimonies and identification evidence from several witnesses despite certain inconsistencies in details such as the description and identification of Segundino Andres.
Despite minor discrepancies in the early identification statements of witnesses such as Celia and Expedito Alfaro, the overall testimony established the presence of the accused at the crime scene.

The Court of First Instance found Ceferino Manuel, Luis Eugenio, and Segundino Andres guilty as principals in the crimes charged.
The sentence imposed included:

Five death penalties for each of the convicted accused, later modified.
Seven indeterminate prison terms (minimum of eight years and one day to a maximum of fourteen years and eight months), not exceeding a total of forty years.
A joint indemnity payment increased in the review (eventually set at P30,000 for each deceased victim’s heirs).

The remaining accused—Felipe Ramillano, Ranulfo Atilano, and Enrique Manuel—were acquitted on grounds of reasonable doubt.
Additional proceedings noted that Luis Eugenio, having absconded during trial, was tried and sentenced in absentia in accordance with the 1973 Constitution then in force.

Whether the witness identifications provided immediately after the incident and at trial, despite being rendered with minor inconsistencies, were sufficient to establish the presence of the accused.
Debate over the credibility of identifications rendered after a lapse of time (as in the case of witness Celia Alfaro and her description of “somebody tall and dark”).

The challenge posed by the variations in the statements of witnesses such as Celia Alfaro, Expedito Alfaro, and Ernesto Alfaro.
Whether the late reconciliation of witness identifications should diminish their evidentiary value or suggest a deliberate intent to distort recollections.

Whether the defenses of alibi offered by the accused were supported by showing not only a presence elsewhere but also the physical impossibility of reaching the crime scene at the relevant time.
Scrutiny of the proximity of the alibi locations:

Ceferino Manuel’s claim of being fourteen kilometers away—a distance deemed traversable in less than an hour.
Segundino Andres’ claimed whereabouts being just about one kilometer from the scene.

Whether the evidence sufficiently established that the accused acted in concert as principals, bound by a common purpose in perpetrating the multiple crimes.