Case Digest (G.R. No. 230825)
Facts:
People of the Philippines v. Abelardo Parungao, G.R. No. 125812, November 28, 1996, Supreme Court Third Division, Melo, J., writing for the Court. The plaintiff-appellee was the People of the Philippines; the accused-appellant was detainee Abelardo Parungao.On May 30, 1989, prisoners in Cells No. 2 and 6 of the Pampanga Provincial Jail at the Provincial Capitol in San Fernando staged a jailbreak. During the escape two jail guards, Conrado Basa and Emilardo Valencia, were killed and another guard, Arnel Aldana, was seriously wounded; six firearms were also taken from the jail armory. An Information dated April 16, 1990 charged Parungao and 15 other prisoners with Robbery with Homicide and Serious Physical Injuries.
Several co-accused were tried earlier in a separate proceeding; four were convicted and two acquitted, and that judgment was affirmed by this Court in People v. Pamintuan, 222 SCRA 716 (1993). Parungao was arraigned January 14, 1990, tried separately, and on March 18, 1991 the Regional Trial Court (Branch 42, San Fernando, Pampanga) found him guilty and sentenced him to life imprisonment and ordered payment of damages (the trial court’s decretal portion is reproduced below).
Prosecution witnesses at Parungao’s trial included prisoners Mario Quito and Ronnie Pilapil, and jail guards Arnel Aldana and Fernando Pacheco. Quito and Pilapil testified that others told them Parungao was the mastermind; Quito said he had seen a letter from Ramon Sevilla allegedly instructing Pabalan and Solis, but the letter was not offered in evidence. Aldana likewise related hearsay that Parungao was the mastermind. Pacheco testified he heard Parungao shout to Briones something rendered in the transcript as, “Alright, go ahead and kill those son of a bitch.” Parungao denied participation, claiming he remained inside Cell No. 1 during the incident and was implicated because he had reported inmates for drug trafficking.
The trial court credite...(Subscriber-Only)
Issues:
- Was the hearsay and uncorroborated testimony admitted at trial sufficient to sustain Parungao’s conviction?
- Was the prosecution able to prove beyond reasonable doubt that Parungao was a co-conspirator and a principal by inducement in the jailbreak, kill...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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