Title
Siccuan vs. People
Case
G.R. No. 133709
Decision Date
Apr 28, 2005
Benjamin de la Cruz was shot and killed in 1982; Constante Siccuan, identified by witnesses, was convicted of homicide. Appeals upheld the verdict, affirming witness credibility and factual findings.
murder conviction
shooting death
credibility of eyewitness testimonies
A

Case Digest (G.R. No. 191537)

Facts:

  • Charges and alleged circumstances of the crime
  • On October 28, 1985, the Office of the Provincial Fiscal of Cagayan charged Constante Siccuan (petitioner) with murder in an Information alleging that on or about September 4, 1982, in the Municipality of Iguig, Province of Cagayan, and within the jurisdiction of the court, petitioner, armed with a gun, with intent to kill, with evident premeditation and with treachery, attacked, assaulted, and shot Benjamin de la Cruz, inflicting gunshot wounds on different parts of his body which caused his death.
  • The Information was founded on the prosecution allegation that the killing occurred on September 4, 1982.
  • Arraignment and trial
  • Upon arraignment on March 21, 1986, petitioner, with the assistance of counsel, pleaded not guilty.
  • Trial ensued after the plea.
  • Prosecution evidence at trial
  • The prosecution presented the circumstances surrounding the victim’s presence and activities.
1) From September 2 to 4, 1982, a team from the Philippine Tobacco Research and Training Center, Mariano Marcos State University, Batac, Ilocos Norte, headed by Benjamin de la Cruz, conducted a training seminar for farm operators at the Cagayan Integrated Agricultural Development Project, Minanga, Iguig, Cagayan. 2) On the evening of September 4, 1982, a program was held to cap the seminar.
  • The shooting incident and eyewitness testimony.
1) At eleven o’clock that night, Benjamin de la Cruz was shot to death. 2) Fidel Udarbe and Dante Claravall witnessed the incident. 3) During trial, both witnesses positively identified petitioner as the malefactor.
  • The postmortem findings.
1) Dr. Edmundo Borja, Rural Health Physician of Tuguegarao, Cagayan, conducted the postmortem examination. 2) Dr. Borja’s findings included the following gunshot wounds:
  • A gunshot wound with split hole point of entrance, approximately 0.9 cm at the left anterior axillary fold; directed posteriorly, upward and to the right; with no point of exit.
  • A gunshot wound with split hole point of entrance, approximately 2 cm at the left anterior axillary fold below the above described gunshot wound; directed posteriorly, upward and to the right; with no point of exit.
  • A gunshot wound at the left hand between the 1st and 2nd metacarpal bones; entrance at the dorsal aspect, oval, approximately 0.6 cm x 1 cm; directed posteriorly, upward and to the left; with point of exit at the palmar aspect, approximately 0.5 cm x 0.6 cm.
  • A gunshot wound, oval approximately 0.7 cm at the mid-epigastric region; directed posteriorly, downward to the left; with point of exit at the postero-lateral aspect of the left lumbar region, approximately 0.6 x 0.9 cm.
3) Dr. Borja opined that the cause of death was shock due to internal hemorrhage due to gunshot wound. 4) Dr. Borja stated that the victim was 30 years old at the time of death.
  • Defense evidence and theory
  • Petitioner was a former member of the Integrated National Police (now Philippine National Police) with the rank of patrolman.
  • At the time of the incident on September 4, 1982, petitioner was assigned to the Regional Security Unit, Regional Command 2, Camp Adduru, Alimanao, Tuguegarao, Cagayan.
  • After the prosecution rested, petitioner filed, with leave of court, a Demurrer to Evidence with Reservation.
  • The trial court denied the demurrer and ordered petitioner to present evidence.
  • Petitioner’s testimony and explanation.
1) Petitioner denied the charge. 2) Petitioner claimed that a member of the New Peoples Army (NPA) must have shot the victim because in his speech during the program, he lambasted the NPA. 3) Petitioner testified that at the time of the incident, he was outside the building where the seminar was being held and about ten (10) meters away from the spot where de la Cruz was shot. 4) Petitioner testified that he heard two gunshots, after which the lights went out.
  • Rulings of the trial court and appellate court
  • Trial court’s judgment.
1) The trial court found petitioner guilty beyond reasonable doubt of homicide (not murder). 2) The penalty imposed was eight (8) years of prision mayor as minimum, to seventeen (17) years and four (4) months of reclusion temporal as maximum. 3) The trial court ordered petitioner to indemnify the heirs of the victim in the amount of fifty thousand (P50,000.00) pesos.
  • Court of Appeals proceedings.
1) On appeal docketed as CA-G.R. CR No. 17996, the Court of Appeals affirmed the trial court’s Decision in toto. 2) Petitioner filed a timely motion for reconsideration. 3) The Court of Appeals denied the motion for reconsideration in its Resolution dated April 28, 1998.
  • Present petition and assigned errors
  • Petitioner filed a petition for review on certiorari challenging the Court of Appeals.
  • Petitioner assigned the following errors:
1) The Court of Appeals committed a fatal and reversible error, if not grave abuse of discretion amounting to lack of jurisdiction, in affirming in toto the lower court’s denial of the demurrer for insufficiency of evidence. 2) The Court of Appeals gravely erred, if not committed grave abuse of discretion, in giv...(Subscriber-Only)

Issues:

  • Whether the Court of Appeals committed reversible error, if not grave abuse of discretion amounting to lack of jurisdiction, in affirming the denial of petitioner’s demurrer to evidence
  • Whether the prosecution evidence at that stage was insufficient such that the demurrer should have been granted.
  • Whether the Court of Appeals erred in crediting prosecution witnesses despite alleged contradictions and inconsistencies affecting credibility
  • Whether alleged discrepancies and initial investigation omissions undermined the credibility of Fidel Udarbe and Dante Claravall.
  • Whether the absence of ballistics and paraffin tests required disbelief of eyewitness testimony.
  • Whether the Court of Appeals erred in affirming conviction for homicide given petitioner’s challenge to evidentiary sufficiency and eyewitness reliability...(Subscriber-Only)

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)
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