G.R. No. L-26195 - People vs. Mejia

The case involves the People of the Philippines as plaintiff-appellee and Dominador Mejia (nicknamed Domingo) as defendant-appellant.
The appeal arises from a judgment rendered by the Court of First Instance of Manila in criminal case No. 72744, where the accused were found guilty of murder.
Apart from Mejia, three co-accused—Rolando Echalar, Ricardo Garcia, and Fidel Capili—were convicted; later, Echalar, Garcia, and Capili withdrew their appeals, leaving Mejia as the sole appellant.

The victim, Victoriano de la Cruz, was killed on the morning of September 28, 1963, shortly after 6:00 o’clock, while crossing G. Perfecto Street in Tondo, Manila.
The fatal injury was inflicted by a .38 caliber bullet that lacerated vital organs such as the diaphragm, liver and its blood vessels, the bile duct, vena cava, and abdominal aorta.
Fidel Capili fired the fatal shot from a position near a bakery approximately fifteen meters away, with Echalar firing concurrently (though Echalar’s shot missed), while the appellant Mejia was positioned near a "talipapa" (public market area) close to the bakery.

The incident took place amid an ongoing rivalry between two gangs: the “Kalaspac Group” (to which the deceased belonged) and the “Dagupan Hunters Group” (to which Capili and Garcia were affiliated).
A prior vendetta had been in motion, as de la Cruz had earlier fired at the mother and brother of Garcia and had shot at Capili’s group at around 3:00 o’clock in the morning on the day of the murder.
In retaliation and to “even up the score,” Capili’s gang targeted de la Cruz throughout the night, culminating in the planned assassination.

Prosecution witness Aurelia de la Cruz testified that she was in her house on 1549 G. Perfecto Street when she heard a shout—“Pasok, mga ulol!”—and observed the four accused with firearms at the corner of G. Perfecto and Linampas Streets.
The spatial arrangement on the scene was as follows: Echalar and Capili were by the bakery; Mejia and Ricardo Garcia were near the “talipapa,” with the distance between the two points being just the width of Linampas Street.
A bystander identified as Pito (Agapito) reported that he was about to cross the street when Mejia fired at him and missed; Pito’s remark, “Bakit ninyo ako babarilin, hindi naman ako ang kalaban ninyo,” suggested confusion about his role in the conflict.

Although there was no direct evidence of an express agreement among the accused, the environmental circumstances and coordinated movements pointed to a conspiracy to exact vengeance against members of the rival gang and, in particular, against de la Cruz.
Rolando Echalar’s command—first “Pasok, mga ulol!” and then “Iyan ang isa, tirahin mo na”—indicated a collective plan and unity of intent among the four accused.
There is an emphasis on the fact that even if Mejia did not directly shoot the victim, his actions, including firing at Pito and fleeing with his co-accused immediately after the incident, established his participation in the conspiracy.

The appellant attempted to defend himself by claiming an alibi, stating that from June 1963 until December 12, 1964, he was in Malasiqui, Pangasinan, engaged in helping his uncle plant rice.
His defense was undermined by positive declarations from witnesses Aurelia de la Cruz and Julia Alagao, who confirmed his presence with the co-accused at the scene at the time of the crime.
His so-called alibi was further discredited when evidence showed that he had been in Malasiqui only after the commission of the crime, and he even returned to Manila as a fugitive, only to be apprehended at Binondo shortly after arriving to pay respects upon his brother’s death.

Whether Dominador Mejia’s actions and presence at the scene sufficiently established his participation in the conspiracy to commit murder, despite not directly shooting the victim.
Whether his physical actions—firing at a bystander (Pito) and subsequently fleeing—constituted active participation in the criminal conspiracy.

Whether the circumstantial evidence, including the coordinated movements, eyewitness testimonies, and the contextual background of the gang rivalry, were adequate to prove the conspiracy beyond a reasonable doubt.
The role of indirect evidence (e.g., the commands given by Echalar) in demonstrating a unified plan among the accused.

Whether Mejia’s defense of being in Malasiqui, Pangasinan during the time of the crime could withstand the contradicting accounts provided by prosecution witnesses regarding his whereabouts.
Whether his actions as a fugitive post-crime further negate the plausibility of an alibi defense.