G.R. No. 71142 - People vs. Maralit

A criminal complaint was filed against four individuals—Romy Pasia, Maning Mendoza, Pedro Pacheca, and Lope Maralit—for the killing of Jaime Cordelin, a 63-year-old resident of Carmona, Cavite, on October 16, 1982.
The accused were employees or affiliated personnel of the International Realty Corporation; Pasia, Maralit, and Mendoza were workers, while Pacheca was their overseer, with Maralit acting as the foreman.
The victim, Jaime Cordelin, had an ongoing land dispute with the Corporation, which set a motive for the crime.

On October 2, 1982, at approximately 7:00 A.M. in Barrio Davilan, Carmona, Cavite, eyewitnesses (Bienvenido and Danilo Cordelin, the victim’s sons) observed the assailants—Maralit, Pasia, Pacheca (later deceased), and Mendoza (at-large)—positioned on an elevated spot (5 to 7 meters high) near the road.
The assailants fired shots at the victim and his sons while they were proceeding to work on their farm. The victim was shot in the back, with subsequent confirmatory evidence including seven empty shells of an M-16 rifle and one empty shell of a .45 caliber pistol found in the area.
The medico-legal necropsy revealed multiple gunshot wounds predominantly at the back of the victim, causing fatal hemorrhages (cerebral, intrathoracic, and intra-abdominal).

Eyewitness accounts provided a clear depiction of the assailants in ambush; the brothers testified that the defendants were crouching with ready firearms when the shots were fired.
Physical evidence collected at the scene included empty cartridge shells and forensic details from the autopsy, underscoring the assault as sudden and treacherous.
Prior to the incident, there were indications of escalating tensions wherein the group had previously forced the victim to relinquish the land and, upon refusal, had set fire to the victim’s huts and agricultural property.

Accused-appellants Maralit and Pasia claimed they arrived at their workplace along with twenty other workers at about 6:30 A.M. on the day of the crime, thus establishing an alibi.
Their attendance was documented in the daily report, signed by Maralit as foreman, and corroborated by various witnesses including the Corporation’s plantation manager, Generoso Panopio, and his daughter.
The defense argued that Maralit’s presence at the worksite precluded his participation in the murder and characterized his involvement as passive since he was not armed.

Whether accused-appellant Lope Maralit participated in the crime merely as a passive onlooker or if he actively conspired with the actual shooters by being physically present at the scene.
Whether his failure to carry a firearm at the time of the incident could exempt him from being held criminally liable under the principle of conspiracy.

The validity of Maralit’s alibi based on the attendance report and testimonies from corroborating witnesses.
Whether the alibi defense can override the positive identification and testimonies of the eyewitnesses who placed him at the elevated hiding spot during the commission of the crime.

Whether the circumstantial and testimonial evidence suffices to establish a conspiracy among the accused despite the absence of direct evidence of their mutual understanding prior to the crime.
The legal sufficiency of circumstantial evidence in proving that the defendants acted in concert to commit the murder.

Questions regarding the appropriate imposition of penalty in view of the abolition of capital punishment under the 1987 Constitution.
The need to modify the sentence, converting the penalty prescribed for Murder under the Revised Penal Code to an indeterminate sentence aligning with the prevailing legal standards.