G.R. No. 138874-75 - People vs. Larranaga

The accused, PO2 Eduardo Valdez and Edwin Valdez, were charged and subsequently convicted on three counts of murder for the fatal shooting of Ferdinand Sayson, Moises Sayson, Jr., and Joselito Sayson.
The incident occurred on March 1, 2000, in Quezon City, where the accused allegedly conspired and acted in concert to commit the crime.
The Regional Trial Court (RTC) rendered a conviction on January 20, 2005, sentencing the accused to reclusion perpetua for each count and ordering payment of various forms of damages to the victims’ heirs.

The incident took place during a family gathering at a canteen and jai alai betting station owned and managed by members of the Sayson family.
At around 9:00 o’clock, after some family members had arrived for the celebration, the accused arrived on a motorcycle at the scene.
Confrontation ensued when Eduardo and Edwin called out to a teller in the betting station, which precipitated the unexpected appearance of Moises Sayson who attempted to defuse the situation.
As eyewitness Estrella Sayson and others observed, the accused, armed with short firearms, threatened and then attacked the victims.
The shooting sequence involved:

An alleged verbal threat directed at Moises before he was shot.
Successive gunshots causing Moises to fall, followed by additional shots that struck Ferdinand and later Joselito.
The victims sustained fatal wounds with evidence corroborated by physical (medico-legal) findings indicating close-range firing.

After the shootings, the accused fled together on the same motorcycle, underscoring the element of joint action.

The State’s case relied on the detailed and consistent testimonies of witnesses such as Estrella Sayson, Susan Sayson, and Marites Sayson, who provided a chronological account of the events.
The physical evidence, including the nature and location of the gunshot wounds as attested by medico-legal reports, supported the confrontation narrative and established that the shots were fired at close range.
The pattern of injuries and sequence of events bolstered the factual findings of a coordinated attack by the accused.

The accused, through the Public Attorney’s Office (PAO), presented a differing version suggesting that:

The victims were aggressive, with one victim allegedly pointing a gun at the accused, prompting a defensive action.
PO2 Valdez contended he dodged a bullet fired by one of the victims and claimed to have played dead to avoid further harm.
His account attempted to recast the roles by implying that the victims initiated the violence.

This narrative was found to be inconsistent with the established facts and the corroborated testimony of the State’s witnesses.

The Court of Appeals (CA) affirmed the RTC’s findings with some modifications regarding the quantum of damages, but later the appeal was narrowed to the appeal of PO2 Eduardo Valdez only, after the withdrawal of the appeal of the other accused.
The CA’s thorough assessment of both testimonial and physical evidence was given deference by the Supreme Court in affirming the case against PO2 Valdez.

Whether the inconsistencies or perceived weaknesses in the testimonies of state witnesses undermined their credibility.
The impact of such supposed inconsistencies on the overall reliability of the evidence presented.

Whether the actions of the accused sufficiently evinced a mutual agreement and common purpose to commit the crime.
The legal basis for inferring a conspiracy from their joint actions despite differences in the level of participation in every detail.

Whether the information sufficiently alleged the presence of treachery as an aggravating circumstance in the commission of murder.
The implications of failing to specify how treachery was employed to ensure the execution of the killings without risk.

The validity of the accused’s contention that the victims were themselves aggressors.
Whether the evidence supports a re-interpretation of the sequence of events as self-defense or reactive conduct on the part of the accused.

Whether the factual allegations in the complaint adequately informed the accused of the nature and cause of the charges against him.
The need for detailed and explicit facts to specifically establish the elements of the crime, including any qualifying circumstances.