G.R. No. 127663 - People vs. Valdez

On September 17, 1995, at about 8:30 in the evening, a shooting incident occurred at Sitio Cabaoangan, Barangay Nalsian, Municipality of Manaoag, Pangasinan.
A group of passengers riding a tricycle—including victims Ramon Garcia, Jr., Jean Marie Garcia, Willie Acosta, Sandra Montano, William Montano, and Randy Tibule—were en route to a dance party when they encountered armed individuals.
Accused Rolando Valdez, together with his companions (one of whom was Bernard Castro and an unidentified John Doe), was implicated in the ambush. Armed with caliber .30 carbines, the assailants fired upon the occupants, resulting in the instantaneous death of Ramon Garcia, Jr., Jean Marie Garcia, Willie Acosta, and Sandra Montano, along with fatal injuries to William Montano and Randy Tibule (which were, however, rendered non-fatal due to timely medical intervention).

Criminal Case No. U-8747 for the complex crime of multiple murder with double frustrated murder, alleged to have been committed in concert with his co-accused.
Criminal Case No. U-8749 for illegal possession of firearms and ammunition under Presidential Decree No. 1866.

The prosecutorial records include detailed descriptions of the injuries sustained by the victims, such as gunshot wounds with specific measurements and trajectories noted in the exhibits.
Multiple eyewitness accounts and investigative affidavits were presented, including conflicting statements regarding the identity of the individual who flagged down the tricycle, thereby forming a crucial part of the evidentiary record.

The trial court rendered a judgment of conviction on October 24, 1996, sentencing the accused to:

Death for the complex crime of multiple murder with double frustrated murder under Criminal Case No. U-8747 (including civil liabilities to the heirs and survivors of the victims).
Reclusion perpetua for violation of Presidential Decree No. 1866 in Criminal Case No. U-8749.

During the trial, discrepancies arose between the earlier affidavits (notably those of William Montano and Randy Tibule) and their in-court testimonies, which the defense later challenged as material, substantial, and significant.
The prosecution maintained that despite inconsistencies related to identification and the withdrawal of some witness charges (notably involving Bernard Castro), the cumulative evidence was sufficient for conviction.

Accused-appellant Rolando Valdez sought reversal of his conviction based on several alleged errors, including:

Failure to dismiss or give due weight to the discrepancies in the statements of prosecution witnesses.
Improper consideration of recantations and issues concerning the identification of the actual gunman.
Misinterpretation of motive, whereby the defendant argued that it was not he but another suspect (Bernard Castro) who actually fired at the victims.
The contention that the police investigators, who were eventually presented by the defense, could have potentially exonerated him if properly considered.

The appellate court undertook a meticulous review of the entire record, including the evidentiary basis concerning both the shooting incident and the alleged possession of an unlicensed firearm.

Whether the discrepancies between the affidavits taken during the investigation and the testimonies rendered in court were material and sufficient to cast reasonable doubt upon the identification of the accused-appellant.
Whether the recantation of witness testimonies regarding the identification of Bernard Castro should have prejudiced the credibility of the prosecution’s case against Rolando Valdez.

Whether the evidence presented by the prosecution adequately established the aggravating circumstance of treachery.
Whether there was sufficient proof to consider the element of evident premeditation as an aggravating factor in the commission of the crimes.

Whether the trial court erred in charging the accused-appellant with a complex crime of multiple murder with double frustrated murder instead of considering the various individual acts as separate counts of murder and frustrated murder.
Whether the illegal possession of firearms charge under Presidential Decree No. 1866 should have been maintained separately or absorbed as an aggravating circumstance in light of Republic Act No. 8294.

The appropriateness of giving credence to the cumulative eyewitness accounts despite some inconsistencies in witness designations and identifications.
Whether the defense’s arguments regarding the non-presentation of certain police investigators (and their subsequent affidavit) warrant the reversal or modification of the conviction and sentencing.