G.R. No. 217024 - People vs. Bolo y Maldo

The case arose from an incident on or about July 18, 2008, in the municipality of Benito Soliven, Isabela, where Brgy. Capt. Artemio Garcia, Sr. was shot and killed.
On January 12, 2009, an Amended Information charged Mario Parris (Panis), Aurelio Santiago, Larry Cilino Flores, and Jerry Magday Galingana with Murder. The allegations emphasized that the accused, conspiring and confederating together, committed the crime with evident premeditation, treachery, and abuse of superior strength.
It was further alleged that during the commission of the crime the accused unlawfully possessed and used firearms without the necessary permits.

Upon arraignment, Panis, Santiago, and Flores pleaded not guilty; however, Panis later died during the pendency of the case while Galingana remains at large.
Arrests were effected immediately after the incident, with Police Chief Inspector Ronald Laggui testifying that Parris and Santiago were apprehended on July 19, 2008 following a prompt investigation.
The accused were subsequently brought to the Isabela Provincial Crime Laboratory for a paraffin test, which yielded results that were positive for Santiago and Galingana and negative for Flores and Parris.

Artemio Garcia, Jr. testified that on the morning of July 18, 2008, he heard gunshots while having coffee and soon witnessed his father, Artemio Sr., being shot.
Jhonny Garcia, another key witness, provided a detailed account of the events, stating that while returning to his house after coffee, he heard gunshots, saw his father hit by bullets, and identified the assailants as Santiago and Panis.
Police Chief Inspector Laggui corroborated the timeline by explaining that he acted on Jhonny’s information at the hospital where the victim was pronounced dead and subsequently arrested the suspects.

The victim’s death certificate and post-mortem reports confirmed multiple gunshot wounds predominantly on the victim’s back.
The paraffin test reinforced the identification of Santiago (and Galingana) as being in possession of the firearms used in the shooting.

Accused-appellant Aurelio Santiago maintained that he was asleep at home with his family at the time of the crime.
Santiago further claimed that prior to the incident, Flores and Panis had visited him at his farm trying to involve him in the killing, an allegation he denied and used to assert his non-participation.
Larry Flores also denied any affiliation with his co-accused, providing an alibi that he was in Brgy. Rogus, Cauayan City, Isabela on July 17, 2008 and only returned to Benito Soliven on the morning of July 18, 2008, after learning of the incident.

The Regional Trial Court (RTC), in its July 24, 2015 Judgment, found Santiago guilty beyond reasonable doubt of Murder while acquitting Flores on the ground of reasonable doubt.
The RTC emphasized the credibility of the eyewitness Jhonny’s identification of Santiago and highlighted the element of treachery present in the crime, noting that the victim was attacked from behind without opportunity to defend himself.
Monetary awards were imposed against Santiago, including civil indemnity, moral damages, exemplary damages, and temperate damages, with an order to pay the heirs of the deceased.

On appeal, Santiago raised several assignment of errors challenging the sufficiency and credibility of the prosecution’s evidence, particularly the identification by Jhonny and the failure of the prosecution to establish all elements of Murder.
The Court of Appeals, in its April 21, 2017 Decision, affirmed the RTC’s judgment with modifications, including the imposition of interest at six percent per annum on the awarded damages.

Whether or not the Court of Appeals erred in upholding the identification of accused-appellant Santiago by the sole eyewitness, despite alleged inconsistencies in his testimony.
Whether the prosecution sufficiently proved all the elements of the crime of Murder, including the qualifying circumstance of treachery.
Whether the defenses of alibi and denial tendered by Santiago were given due consideration, and if they could negate the positive identification made by the eyewitness.
Whether the imposition of the penalty of reclusion perpetua and the modification in the award of damages, including interest, were proper and supported by the evidence.