G.R. No. 175210 - Sereno vs. Committee on Trade and Related Matters of the National Economic and Development Authority

On March 11, 1983, at about 11:30 p.m., Edmundo Abadilla, while dining at Meding’s Restaurant in Cavite City, detected the smell of marijuana emanating from a nearby table.
The table was occupied by Vicente Capalad and the accused-appellant, Napoleon Montealegre.
Abadilla, intending to notify the authorities, quietly exited the restaurant and encountered Pfc. Renato Camantigue in his car.
Camantigue, upon being hailed by Abadilla, joined him in returning to the scene at the restaurant.

Camantigue and Abadilla observed the presence of Montealegre and Capalad at the table, which had emanated the odor of marijuana smoke.
Camantigue approached the two individuals and questioned them; he even inquired of the waitress about their identities, though she did not provide any identifying information.
The situation escalated rapidly into a physical confrontation as tensions heightened.

While Camantigue was holding Montealegre and Capalad, Vicente Capalad suddenly produced a knife from a scabbard tucked at his waist.
Capalad began stabbing Camantigue in the back repeatedly, inflicting severe wounds.
Concurrently, Montealegre restrained Camantigue by firmly holding his hand, thereby preventing the policeman from drawing his gun to defend himself.

Testimonies revealed that Montealegre used both hands to hold Camantigue’s hand.
The restraint effectively immobilized Camantigue, leaving him vulnerable to Capalad’s assault.

Amidst the struggle, all three men fell to the floor, after which Capalad freed himself to flee toward the door.

In the confusion, Camantigue fired his weapon in a desperate bid to pursue Capalad, who then sought refuge in a dark alley.
Both Camantigue and Capalad eventually succumbed to their injuries; Camantigue died the following day.
Meanwhile, the accused-appellant, Montealegre, managed to escape during the disturbance.
However, he was apprehended on the morning of March 12, 1983, aboard a vehicle headed for Baclaran, initially giving a false name before admitting his identity as the fugitive.

Eyewitnesses, notably Abadilla and Generoso San Juan, provided detailed accounts of the incident, including the sequence of events and the positions of the individuals involved.
Abadilla’s testimony specifically recalled that Montealegre restrained Camantigue with both hands just as Capalad was inflicting lethal stab wounds.
San Juan corroborated that Montealegre was conspicuously positioned on the right side of Camantigue, preventing the policeman from drawing his gun.
Medical evidence, including the autopsy report by Dr. Regalado Sosa, confirmed that Camantigue suffered seven stab wounds affecting vital organs, with shot evidence (blood analysis on the weapon) corroborating the violent nature of the attack.

Montealegre’s own testimony was marked by contradictions, evasions, and denials, which conflicted with the compelling witness accounts.
He claimed to have escaped before the stabbing occurred, yet evidence and testimony established that he was actively involved in restraining Camantigue during the assault.
Montealegre’s failure to accurately describe his position and actions on the night of the incident further undermined his defense and reinforced the prosecution’s narrative.

The incident led to the filing of charges against Montealegre for murder with assault upon a person in authority.
The prosecution portrayed him as a co-principal in the killing of Pfc. Camantigue based on his indispensable cooperation with Capalad.
The trial court found that despite not being the one who directly stabbed Camantigue, Montealegre’s act of holding the victim’s hand was crucial in enabling the murder.
Consequently, the accused-appellant was convicted under the principle of principal by indispensable cooperation as provided under Article 17, paragraph 3, of the Revised Penal Code.

Whether Montealegre’s act of restraining Pfc. Camantigue’s hand, thus preventing him from drawing his weapon, constitutes sufficient participation in the crime of murder.
Whether his physical involvement, as corroborated by multiple eyewitnesses, was indispensable to the execution of the crime, thereby justifying his classification as a co-principal.

Whether the contradictions and evasive nature of Montealegre’s own testimony could be reconciled with the consistent and detailed accounts provided by eyewitnesses like Abadilla and San Juan.
Whether the prosecution’s evidence, including forensic and medical reports, adequately supports the inference of a common criminal purpose between Montealegre and Capalad.

Whether the circumstances of the case satisfy the requisites under Article 17, paragraph 3 of the Revised Penal Code for imputing principal liability through indispensable cooperation.
Whether the absence of a prior formal conspiracy undermines or maintains the legal basis for holding Montealegre legally responsible as a co-principal in the commission of the murder.