Case Digest (G.R. No. 47388)
Facts:
People of the Philippines v. Mariano R. Marcos et al., G.R. No. 47388, October 22, 1940, the Supreme Court En Banc, Laurel, J., writing for the Court.In the 1934 elections Mariano Marcos and Julio Nalundasan, both of Batac, Ilocos Norte, were rival candidates for representative; Nalundasan won. Under the new Constitution general elections were set for September 17, 1935; in those elections Nalundasan again defeated Mariano Marcos, and celebrations by Nalundasan’s partymen included a parade through Currimao, Paoay and Batac on September 19, 1935, which allegedly humiliated the defeated candidate. On the night of September 20, 1935, Julio Nalundasan was shot and killed in his house at Batac.
Initial investigation led to the prosecution of Nicasio Layaoen, who was later acquitted. After further investigation, on December 7, 1938, an information was filed in the Court of First Instance (CFI) of Ilocos Norte charging Mariano R. Marcos, Pio Marcos, Ferdinand Marcos, and Quirino Lizardo with murder for the September 20, 1935 killing. During the trial the principal witness for the prosecution was Calixto Aguinaldo, who testified that he participated in planning and was present during the killing.
On June 10, 1939, before the principal trial concluded, the four accused filed separate complaints for false testimony against Aguinaldo before a justice of the peace; the provincial fiscal moved to provisionally dismiss those complaints and later moved to have the defendants held in contempt. After trial the CFI found Ferdinand Marcos and Quirino Lizardo guilty beyond reasonable doubt of murder (with specified aggravating and mitigating circumstances) and sentenced them (including indeterminate penalty for Ferdinand), acquitted Mariano and Pio Marcos of murder, and adjudged all four guilty of contempt for filing the false testimony complaints, fining each P200 (with subsidiary imprisonment in default).
Ferdinand Marcos and Quirino Lizardo appealed from their murder convictions to the Supreme Court, assigning errors regarding witness credibility, inconsistent verdicts, use of character evidence, evidentiary rulings, denial of motions to reopen or for new trial, and the con...(Pro-only)
Issues:
- Was the testimony of Calixto Aguinaldo, the principal witness, sufficient to sustain the convictions of Ferdinand Marcos and Quirino Lizardo for murder beyond a reasonable doubt?
- Was the CFI correct in finding Mariano, Pio, Ferdinand Marcos and Quirino Lizardo guilty of contempt for filing premature complaints charging Aguinaldo with false testimo...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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