Case Digest (G.R. No. 132069)
Facts:
People of the Philippines v. Jose T. Obosa, G.R. No. 132069, May 31, 2000, Supreme Court Third Division, Gonzaga‑Reyes, J., writing for the Court.The prosecution filed two Informations on December 4, 1987 in the Regional Trial Court of Makati charging Jose T. Obosa and others with murder for the August 2, 1987 ambush that killed then Secretary of Local Government Jaime N. Ferrer and his driver Jesus D. Calderon. The Informations alleged conspiracy and specified qualifying circumstances including treachery, evident premeditation, abuse of superior strength, nighttime, and acting by a band.
Medical and ballistics evidence introduced at trial showed Secretary Ferrer suffered multiple gunshot wounds (autopsy indicating five fatal wounds to head and neck) and Calderon sustained five gunshot wounds; ballistic analysis linked bullets found to .38‑ and .45‑caliber firearms. At trial the RTC made detailed factual findings based primarily on eyewitness testimony from Sonia Alata, Victor Gomez and George Montabon, and on a post‑incident confession allegedly made by Obosa to fellow inmate Ricardo Palquerra. The RTC found those witnesses credible, concluded the acts established appellant's guilt beyond reasonable doubt, and on May 25, 1990 convicted Obosa and co‑accused Nieves Constancio of two counts of homicide (Art. 249, Revised Penal Code), sentenced them to indeterminate terms, ordered indemnities to heirs, and acquitted Victoriano Totaan for lack of proof.
On appeal the Court of Appeals reviewed the record, concluded the killings were qualified by treachery and merited conviction for two counts of murder (Art. 248, Revised Penal Code), and because the applicable penalty was reclusion perpetua refrained from entering final judgment and referred the case to this Court. Obosa advanced defenses that the eyewitnesses were inconsistent or coached, that prison records established a physical alibi (he was in the National Bilibid Prison), and that the alleged confession to Palquer...(Pro-only)
Issues:
- Did the discrepancies in the prosecution witnesses’ accounts require reversal of the conviction for lack of credible identification of Jose T. Obosa?
- Did the evidence establishing that Obosa was an inmate at the National Bilibid Prison make his presence at the crime scene physically impossible and thus exculpatory?
- Could the testimony of Ricardo Palquerra, a convicted felon and cellmate, be admitted and given weight against Obosa?
- Were the killings qualified by treachery such that the proper crime is mur...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)