G.R. No. 115217 - People vs. Paredes Jr.

On April 12, 1989, around 5:00 p.m., Amelito Banug and Evangelio Asis Jr. were returning home along Kauswagan, Cabacungan, Barobo, Surigao del Sur.
They encountered the brothers Danny Paredes and Santos Paredes Jr. (alias “Titing”), with Danny carrying a long firearm and Santos Jr. holding a knife.
Sensing impending trouble, Amelito and Evangelio attempted to flee, but a burst of gunfire was heard.
Amelito noticed Danny firing at Evangelio, causing Evangelio to fall wounded; subsequently, Santos Jr. stabbed the already fallen Evangelio.
Amelito alerted Evangelio’s parents immediately and later returned with them to find Evangelio lifeless, having sustained four gunshot wounds and two stab wounds.

On January 9, 1991, the brothers Danny Paredes and Santos Paredes Jr. were charged with murder before the Regional Trial Court of Lianga, Surigao del Sur.
Both defendants raised an alibi defense.

Danny claimed that on April 8, 1989, he was shot in the right ear by Evangelio’s father for allegedly refusing to extend credit for wine, resulting in his confinement at the Provincial Hospital at Patin-ay, Prosperidad, Agusan del Sur until April 20, 1989.
His medical certificate and the testimony of Legaspi Marayno, who attended to a patient in the same hospital room, were used to substantiate his claim.

Santos Jr. also asserted an alibi defense; however, his explanation was discounted based on:

Positive identification by Amelito, who testified seeing him at the scene.
The trial court’s finding that Santos Jr. possessed the physical capability and motive to commit the crime.

On February 7, 1994, the trial court acquitted Danny Paredes based on his reliable alibi.
Conversely, Santos Paredes Jr. was found guilty of murder.

Santos argued that there was clear and convincing evidence establishing his absence from the crime scene.
He further contended that even if found guilty, his age (fifteen years old at the time of the offense) entitled him to the privileged mitigating circumstance of minority.
He challenged the reliability of Amelito’s testimony by drawing a parallel to the reasoning given for Danny’s acquittal, despite Danny’s alibi being upheld through the medical certificate.

The defense’s medical certificate, issued by Dr. Norberto S. Reyes, indicated Danny’s confinement from the night of April 8, 1989 to April 20, 1989.

There appeared an ambiguity concerning the duration of Danny’s confinement, with indications that the originally noted “10 April” might have been altered to “20 April” through superimposition of the number “2”.

No clarification or additional evidence (such as clinical records or explanation by the physician) was provided to resolve this ambiguity.
The trial court, however, maintained a distinction by accepting only portions of Amelito’s testimony, crediting it for implicating Santos Jr. despite entertaining the alibi for Danny.

Whether the same eyewitness testimony (that of Amelito) could be selectively accepted to confirm the guilt of Santos Jr. while exonerating Danny based on the opposing alibi and medical evidence.
The proper evaluation of the conflicting evidence and credibility of the witness, particularly in relation to alleged alterations in the medical certificate.

Whether the alibi provided by both defendants, particularly supported by a medical certificate in Danny’s case, is reliable given the potential ambiguity and alteration in the documentation.
The extent to which existing evidence supports or undermines the claim of alibi, including travel time estimates and physical impossibility of the accused being at the scene.

Whether Santos Jr., if proven guilty, should benefit from the mitigating circumstance of being a minor (fifteen years old at the time of the offense).
The correct interpretation and application of relevant provisions under the Revised Penal Code and the Child and Youth Welfare Code in reducing the penalty in accordance with his age.