Title
People vs. Moises y Sanidad
Case
G.R. No. L-32495
Decision Date
Aug 13, 1975
Three brothers attacked and killed a man using a firearm, bolo, and stone in 1969. Despite alibis, eyewitness testimony and evidence led to their conviction for murder, with two sentenced to death and the minor to a reduced penalty.

Case Digest (G.R. No. L-32495)
Expanded Legal Reasoning Model

Facts:

  • Case Background and Charges
    • The case involves three accused brothers: Florentino Moises y Sanidad, Eusebio Moises y Sanidad, and Baltazar Moises y Sanidad, charged with the crime of murder under Article 248 of the Revised Penal Code.
    • The murder of Jose Soloria, a school janitor from San Manuel, Pangasinan, occurred on July 19, 1969, at approximately 12:55 P.M. in Guiset Norte, Poblacion, San Manuel.
    • The information in the charge stated that the accused conspired, mutually assisted one another, and executed the murder with evident premeditation and treachery using a .45 caliber pistol, a bolo, and a stone.
  • Details of the Crime and Autopsy Findings
    • The crime scene was documented with multiple wounds on the victim, as detailed in the autopsy report:
      • A lacerated wound on the head, fractures of the parietal bones, and incised wounds on the neck and back.
      • Multiple bullet wounds were noted, with one entrance wound on the back and others on the neck and chest, all contributing to the victim’s death by shock from extensive hemorrhages.
    • The prosecution relied on physical evidence such as recovered empty shells, a bullet, and a sketch drawn up by the investigating police chief.
  • Prosecution’s Evidence and Testimonies
    • The sole eye-witness, Alejandro Tuvera, testified that he observed the sequence of events:
      • Accused Florentino Moises fired a .45 caliber pistol from behind the victim, striking him fatally with successive shots.
      • Following the shooting, accused Eusebio Moises hacked the victim with a bolo while accused Baltazar Moises struck him with a stone.
    • Additional testimonies were provided by police officers (such as Police Chief Marcelino Aquino and Pat. Fernando Alvear) who confirmed:
      • The recovery of evidence near the crime scene.
      • The establishment of the nearby proximity of witnesses Mendoza and Pascua who, though less detailed, supported the basic facts of the case.
    • The autopsy report by Dr. Ananias Ramos further corroborated the sequence and nature of wounds which pointed to a swift and violent attack.
  • Defense’s Arguments and Alibi Claims
    • All three accused interposed a defense of alibi by presenting detailed testimonies to show they were elsewhere when the crime occurred:
      • Florentino Moises testified he was working at a dike construction project in Barrio Cavite, claiming it was impossible to travel from there to the crime scene in time.
      • Eusebio Moises asserted he was in Novaliches, Quezon City, engaged in activities related to work and examinations for the Philippine Marines.
      • Baltazar Moises maintained that he was at the Urdaneta Emergency Hospital visiting his injured father.
    • The defense questioned the credibility of the sole eyewitness by highlighting:
      • His familial connection with the victim, suggesting possible bias.
      • His act of seeking cover, which could allegedly have interfered with his ability to observe the events clearly.
      • The fact that he delayed giving his written statement for 12 days.
  • Rebuttal Testimonies and Evidence Reinforcing the Prosecution
    • Rebuttal witnesses such as Police Chief Marcelino Aquino and Sgt. Ernesto Mercado provided testimony that:
      • Contradicted the alibi claims by establishing the feasible travel time between locations.
      • Supported the identification of the accused by reinforcing the presence of the accused near the scene as observed by Alejandro Tuvera.
    • The consistency in physical evidence, eyewitness account, and investigative findings undermined the defense’s claim of alibi and mitigated allegations of witness bias.
  • Judicial Considerations on Witness Credibility and Evidence
    • The trial court conducted a meticulous evaluation of the eyewitness testimony, particularly focusing on the demeanor, detailed narrative, and corroborative aspects despite the delay in the written statement.
    • The allegations of bias due to the witness’s kinship with the victim were deemed insufficient to discount his testimony, especially as his account was supported by other evidence such as the recovered physical evidence and the testimonies of other witnesses.

Issues:

  • Credibility of the Eyewitness Testimony
    • Whether the sole testimony of Alejandro Tuvera—who directly implicated the accused brothers in the commission of the crime—is reliable and free from undue bias despite his familial relation with the victim.
    • Whether the detailed and seemingly “too good to be true” aspects of his account affect its overall credibility.
  • Validity of the Alibi Defense Presented by the Accused
    • Whether the alibi testimonies offered by Florentino, Eusebio, and Baltazar Moises sufficiently exonerate them from being present at the scene of the murder.
    • The plausibility of the alleged timelines as coordinated by the accused versus the established sequence of events.
  • Consistency and Corroboration Between Physical and Testimonial Evidence
    • How the physical evidence (bullet findings, empty shells, autopsy details) aligns with the testimonies provided by the witnesses.
    • Whether discrepancies in the defense accounts contradict the established evidence.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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