Case Summary (G.R. No. 69184)
Case Background
Mario Ablao was accused of murdering Andres Manambit, Sr., during a session of the Sangguniang Bayan in Lumban on December 16, 1977. The Regional Trial Court of Laguna found Ablao guilty and imposed the death penalty, attributing aggravating circumstances to the crime due to the victim's rank as Barangay Captain.
Prosecution's Evidence
The prosecution presented Lt. Domingo Gapas, who testified to witnessing Ablao shoot Manambit. Other witnesses corroborated the event, stating that they saw Ablao with a firearm immediately after the shooting. The victim sustained multiple gunshot wounds, as outlined in Dr. Maximo Reyes’s autopsy report, which established the cause of death as a gunshot wound to the head. Circumstantial evidence indicated that Ablao fled the scene and was in possession of a firearm similar to the one used in the murder.
Defense's Argument
Ablao's defense revolved around his assertion that he did not shoot the victim and claimed the gun he carried was handed to him by his brother, Mayor Bruno Ablao. He described his subsequent flight as an act of fear and confusion following the incident. The defense sought to undermine the prosecution's claims by arguing lack of motive and clear evidence linking Ablao to the murder.
Court's Findings
The appellate court upheld the trial court’s initial ruling of murder based on the considerable circumstantial evidence implicating Ablao. However, it determined that the specific qualifying circumstances of treachery and evident premeditation, as alleged in the information, were insufficiently substantiated. The court also acknowledged the absence of evidence establishing that the firearm used was unlicensed.
Aggravating and Mitigating Circumstances
The appellate court confirmed the aggravating circumstance of disregard of rank, as Ablao shot a recognized public official during an official session. However, it found no basis for the qualifying circumstances of treachery and evident premeditation, ultimately downgrading Ablao's conviction from murder to homicide.
Final Ruling
The court modified the original judgment, declaring Mario Ablao guilty
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Case Overview
- The case involves an appeal from the Regional Trial Court of Laguna, Branch 26, concerning the conviction of Mario Ablao for the murder of Andres Manambit, Sr.
- The trial court sentenced Ablao to death, citing aggravating circumstances related to the victim's rank as Barangay Captain and President of the Association of Barangay Captains in Lumban, Laguna.
- Co-accused Alberto Almario, Zenon Samonte, Hector Samonte, and Bruno Ablao were acquitted due to lack of evidence.
Factual Background
- The incident occurred on December 16, 1977, during a session of the Sangguniang Bayan in Lumban, Laguna.
- The information charged all accused with conspiring to murder Andres Manambit, inflicting multiple gunshot wounds that led to his death.
- Prosecution evidence pointed to Mario Ablao as the shooter, with testimonies from police and witnesses supporting this claim.
Prosecution Evidence
- Lt. Domingo Gapas: Witnessed Mario Ablao shoot Manambit and identified him as the assailant. Gapas attempted to pursue Ablao but found Manambit dead upon returning.
- Dr. Maximo Reyes: Conducted the autopsy, revealing multiple gunshot wounds. The cause of death was determined to be hemorrhage from a gunshot