Case Summary (G.R. No. 129072)
Incident Overview
On February 18, 1996, at approximately 5:30 PM, Flordeliza Golocan was preparing food when she observed through a window that her husband, Julius, was speaking to Antonio Abubu and his companions. Subsequently, the group attacked, firing upon Julius, Flordeliza, and their two young children, John Paul and Noemi. The assault resulted in Julius's death and critical injuries to the other family members. Law enforcement was alerted, leading to the investigation and response from the Cauayan Police.
Investigation and Evidence
Upon their arrival, police officers discovered the scene, evidencing the brutality of the attack with a deceased Julius Golocan on the floor and Flordeliza and the children suffering from gunshot wounds. Two empty .357 revolver shells were recovered from the scene. Flordeliza identified Abubu and Jesus Valdez as perpetrators, leading to subsequent manhunts for them and the others involved, although some co-accused remained at large.
Medical Treatment and Testimony
The injured family members were transferred to various hospitals for treatment, where medical professionals provided testimonies about the nature and severity of their injuries. Flordeliza had a gunshot wound to her right arm, which nearly proved fatal without timely medical attention. John Paul suffered a grievous head injury, while Noemi sustained gunshot wounds to her feet, all of which were described as life-threatening without immediate intervention.
Accused's Defense
During the trial, Antonio Abubu claimed he had arrived at the scene, spoke with Julius, and left before the shooting unfolded, stating he heard the gunshots from a distance. Conversely, Jesus Valdez denied his involvement and testified in his defense, highlighting a lack of identification by Flordeliza regarding his participation in the crime.
Court's Findings and Verdict
The Regional Trial Court of Cauayan acquitted Jesus Valdez due to insufficient evidence, while it convicted Antonio Abubu of murder and sentenced him to death, alongside multiple counts of frustrated murder for the assaults on Flordeliza and her children. The court found credible evidence from Flordeliza’s testimony, reinforcing her identification of Abubu as an assailant. Additional circumstantial evidence, such as Abubu’s actions post-incident and the nature of the attack, corroborated the charges.
Legal Analysis on Conviction
Upon appeal, the court reviewed the definition of a complex crime as outlined in Article 48 of the Revised Penal Code and determined that the distinct acts of shooting did not qualify as a complex crime, as each act of violence was separate and attributable to
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Case Background
- Antonio Abubu y Valdez, alias "Boy Valdez," and his accomplices, including Jesus Valdez y Bueno, Oscar Dimarucut, Renato Manabat, and Rey Manabat, were charged with murder and multiple counts of frustrated murder following an incident on February 18, 1996.
- The victims, Julius Golocan and his family, lived in Barangay Pinoma, Cauayan, Isabela. Julius was shot dead, while his wife Flordeliza and their two children, John Paul and Noemi, sustained serious injuries.
- The incident occurred when Flordeliza answered a knock at their door, revealing the accused and his companions, who then opened fire on the family.
Incident Details
- On the day of the incident, Flordeliza was preparing food when she noticed the accused. Julius opened the door, and after a brief conversation, the group attacked.
- Julius was shot while carrying John Paul, and Flordeliza was shot while holding Noemi.
- The shooting resulted in Julius's death and critical injuries to Flordeliza and the children.
- Evidence from the scene included two empty shell casings and numerous bullet holes in the walls of their home.
Medical Examination and Testimonies
- Julius's post-mortem examination revealed five gunshot wounds, with the cause of death attributed to massive hemorrhage from gunshot wounds.
- Flordeliza sustained a gunshot wound to her arm, which lodged near her lung, while her children suffered life-threatening injuries.
- Medical prof