G.R. No. 160739 - Mangila vs. Pangili

The case arose from a long-standing territorial dispute over a piece of land in Goliptoc, Dumingag, Zamboanga del Sur.
The deceased, Maximo Candia, along with eyewitness Cleto Baranda, had purchased rights in the property from a person named Subano.
Appellants, Eleno Tapitan and his son Enriquito Tapitan, were convinced that the disputed land rightfully belonged to them, evidenced by the presence of a house owned by Eleno Tapitan on the premises.

On the morning of April 9, 1958, tensions over the disputed property culminated in a violent confrontation.
Eyewitness Cleto Baranda testified that early that morning, around six o’clock, after transporting posts for building a house, he encountered Eleno Tapitan armed with a revolver and a bolo.
Despite Baranda’s and Candia’s appeals to resolve the matter by discussion, Eleno Tapitan escalated the confrontation, issuing a command to “come on, you shoot.”
Following this command, Enriquito Tapitan, positioned behind a banana grove and armed with a homemade shotgun (paliuntod), fired at the deceased.
The shooting was confirmed by further evidence: subsequent shots from Eleno Tapitan’s revolver also contributed to the fatal injuries suffered by Candia.

One bullet wound, approximately 12 inches in diameter, was located on the back near the spinal column.
Another wound, about the size of a ten-centavo coin, was found on the right side of the abdomen with an associated protrusion of flesh.
A pair of wounds on the left thigh, described as being very close to each other, confirmed the occurrence of multiple gunshots.

Eyewitness testimony, especially that of Cleto Baranda, was pivotal in establishing the sequence of events, including the roles played by both Eleno and Enriquito Tapitan.
Additional testimonies from witnesses such as Subano and Sergio Asequia corroborated the presence of the accused at the scene of the crime.

In an attempt to evade criminal liability, the accused advanced a defense based on alibi. They claimed that on the morning of April 9, 1958, they were in Ozamis City.
Their alibi was supported by the testimony of a witness, Maximo Leonardo, who stated that he saw Enriquito Tapitan (along with Mario Malagar) at a vulcanizing shop in Ozamis City.
Both accused further testified that they were in Ozamis City during the time of the incident, a claim that conflicted with multiple other eyewitness accounts.
The court noted that the mere assertion of being elsewhere is not compelling without credible corroboration, especially when weighed against the strong evidence placing them at the scene.

At trial, all accused were charged with murder. The lower court found Eleno Tapitan and Enriquito Tapitan guilty of the crime and sentenced them to death, while Precioso Tapitan, who opted for voluntary surrender and received reclusion perpetua, did not appeal.
The lower court’s findings were heavily supported by detailed eyewitness testimonies, forensic evidence, and the established credibility of multiple witnesses.
Discussions on the previously settled legal principles regarding alibi and conspiracy further framed the context in which the case was assessed.

Whether the accused’s claim of being in Ozamis City on the morning of April 9, 1958, stands against the overwhelming testimony that placed them at the scene of the crime.
The sufficiency of the alibi evidence presented by the accused compared to the direct and corroborative testimony of multiple eyewitnesses.

Whether the collective actions of Eleno Tapitan and Enriquito Tapitan, including the simultaneous firing of their weapons, establish a conspiracy that renders both liable as co-principals in the commission of murder.
The applicability of established doctrines and precedents concerning joint criminal liability in the context of the factual circumstances of the case.

Whether the trial court correctly applied the evidentiary record, including the forensic details and witness accounts, in determining that the murder was committed with evident premeditation and treachery.
The extent to which the principles of conspiracy—as derived from prior case law—support the conviction of both accused as active participants in the criminal act.