G.R. No. 47388 - People vs. Marcos

In the 1934 elections for the office of representative for the second district of Ilocos Norte, Mariano Marcos and Julio Nalundasan were rival candidates.
Julio Nalundasan emerged victorious; however, his term was cut short due to the new Constitution, which mandated elections for the National Assembly on September 17, 1935.
In the ensuing 1935 general elections, the same political rivalry resurfaced with Nalundasan again defeating Mariano Marcos.

On the afternoon of September 19, 1935, supporters of Nalundasan paraded in vehicles through several municipalities (Currimao, Paoay, and Batac) and passed by the Marcos residence in Batac.
The parade was described as both provocative and humiliating for the defeated candidate, Mariano Marcos.

On the night of September 20, 1935, amidst the political tension following the parade, Julio Nalundasan was shot and killed in his residence at Batac.
The murder prompted intensive investigations by government authorities, particularly the Philippine Constabulary and the Division of Investigation of the Department of Justice.

An information was first filed against Nicasio Layaoen, a Batac businessman, charging him with the murder of Nalundasan.
After a trial in the Court of First Instance of Ilocos Norte, Layaoen was acquitted, leading to renewed and more extensive investigative efforts.
On December 7, 1938, more than three years after the murder, an information was filed charging four defendants—Mariano Marcos, Pio Marcos, Ferdinand Marcos, and Quirino Lizardo—with the crime of murder.
The information detailed that the accused, allegedly armed with firearms, conspired with a premeditated intent to kill Nalundasan using an automatic pistol and a revolver, with the fatal shot allegedly coming from Ferdinand Marcos.

Calixto Aguinaldo emerged as the principal witness for the prosecution, testifying that he had been involved in various meetings and conspiracies leading up to the murder.

Aguinaldo claimed he attended a meeting at the Marcoses’ residence on the morning of September 15 and other gatherings on September 20.
His testimony implicated him as playing a “watcher” role during the commission of the crime, asserting that Ferdinand Marcos fired the fatal shot while Nalundasan’s back was turned.

Questions arose regarding the credibility of Aguinaldo because he had remained silent for about three years before breaking his silence in November 1938 only after pressure from government agents.
Additional evidence from a previous case against Layaoen—such as witness identification of a man possessing a revolver and the discovery of ammunition—was referenced by the prosecution but had resulted in Layaoen’s acquittal.

On June 10, 1939, prior to the conclusion of the trial, separate complaints were filed by each of the accused (Mariano Marcos, Pio Marcos, Ferdinand Marcos, and Quirino Lizardo) against Calixto Aguinaldo.
The charges alleged that Aguinaldo committed the offense of false testimony during the preliminary investigation of December 7, 1938, and during the trial.
The trial court, acting on the provincial fiscal’s motion, provisionally dismissed these complaints and later ordered the accused to show cause for contempt.
Upon the main trial’s conclusion regarding the murder charge, the Court of First Instance rendered a judgment:

Quirino Lizardo and Ferdinand Marcos were found guilty of murder, with aggravating and mitigating circumstances considered for each respectively, and were sentenced with reclusion perpetua and a fixed indeterminate penalty, along with fines and indemnity payments.
Mariano Marcos and Pio Marcos were acquitted of murder; however, all accused were found guilty of contempt for their actions concerning the false testimony charges and were fined accordingly.

Whether the trial court erred in giving undue credibility to the testimony of the principal prosecution witness, Calixto Aguinaldo, despite his long silence and subsequent contradictory statements.
Whether the inconsistencies in Aguinaldo’s account should have lessened or nullified the evidence against the accused.

Whether it was proper for the trial court to convict two accused (Ferdinand Marcos and Quirino Lizardo) and acquit two (Mariano Marcos and Pio Marcos) based on the same body of evidence.
Whether the admission or rejection of evidence—such as the electoral census (Exhibit 84)—affected the fairness of the trial.

Whether the trial court erred in considering the character of Quirino Lizardo and inferring any predisposition towards violence or political extremism.
Whether motive alone, particularly arising from electoral defeat and subsequent insult, suffices as proof of a criminal conspiracy to commit murder.

Whether the denial of the motions for reopening and a new trial by the accused was justified in light of the potentially tainted evidence and inconsistent witness testimony.

Whether the trial court properly exercised its inherent power to punish for contempt in connection with the false testimony complaints against Calixto Aguinaldo.
Whether the imposition of the contempt fines was consistent with the principles of preserving the administration of justice rather than serving vindictive purposes.