Sison vs. People

Facts:

In the politically charged aftermath of the 1986 EDSA Revolution, supporters of the deposed President Marcos ("Marcos loyalists") staged a rally at Luneta on July 27, 1986, where antagonism toward President Aquino's supporters ("Coryistas") erupted into violence and resulted in the mauling and later death of Stephen Salcedo. Multiple informations were filed between August and October 1986 against several persons identified as loyalists; these criminal cases were consolidated and raffled to the Regional Trial Court (RTC), Branch XLIX, Manila. All accused pleaded not guilty and trial proceeded.

The prosecution presented eyewitnesses (notably Ranulfo Sumilang and Renato Banculo), police witnesses, photographs and newspaper clippings showing the attack. The prosecution picture: a large group of loyalists at Luneta chased and beat Salcedo with fists, kicks and stones; Salcedo sustained extensive cranial fractures and died of intracranial hemorrhage. Defendants offered alibis (some denying presence; others admitting presence but denying assault); several (including Attorneys Lozano and Nuega, and Annie Ferrer) did not testify.

On December 16, 1988, the trial court convicted Romeo Sison, Nilo Pacadar, Joel Tan, Richard de los Santos and Joselito Tamayo as principals of murder qualified by treachery and sentenced them to reclusion temporal; Annie Ferrer was convicted as accomplice; several others were acquitted. The Court of Appeals (CA), on December 28, 1992, modified the RTC decision: it acquitted Annie Ferrer, found Sison, Pacadar, Tan and Richard de los Santos guilty of murder qualified by abuse of superior strength and sentenced them to reclusion perpetua, and convicted Tamayo of homicide (not murder) with an indeterminate penalty. Because reclusion perpetua was imposed on four, the CA certified the cases to the Supreme Court for automatic review (G.R. Nos. 114931-33); the accused filed a separate Rule 45 petition (G.R. Nos. 108280-83) challenging the CA's disposition as to Tamayo.

Appellants raised multiple assignments of error: challenging the credibility of eyewitnesses (allegedly...(Pro-only)

Issues:

• Did the Court of Appeals err in sustaining the trial court's credibility findings and reliance on the eyewitnesses' testimonies?
• Were the photographs and documentary exhibits improperly admitted and did their admission prejudice the accused?
• Was the killing of Stephen Salcedo murder (qualified by abuse of superior strength and under conspiracy) or death in a tumultuous affray (homicide) under Article 251 of the Revised Penal Code?
• Was there a conspiracy among the accused such that each is liable for the acts of the others?
• Were the awards of actual, moral and other damag...(Pro-only)

Ruling:

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Ratio:

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Doctrine:

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