Case Summary (G.R. No. 138386-87)
Charges and Background Information
On June 29, 1998, following the events of June 27, 1998, the appellants were charged with murder under two separate informations (Criminal Cases Nos. 5176 and 5177). The charges stemmed from a shooting incident where Dominador Castro and Mamerto Nalangan were attacked and killed while crossing the Jal-O river in Barangay Oquendo. The prosecution alleged that the appellants, along with two other accused who remain at large, conspired to kill the victims using long shotguns. The specifics of the injuries inflicted upon the victims, as detailed in the post-mortem examination reports, supported the murder claims.
Proceedings and Trial
Upon arraignment, the appellants pleaded not guilty, and a consolidated trial followed. The key evidence presented by the prosecution was the eyewitness testimony of Adoracion Castro, the widow of Dominador, who claimed to have witnessed the shooting from a short distance. Her consistent and detailed account of events, along with forensic evidence, was pivotal in establishing the facts surrounding the crime.
Defense Strategy
The appellants relied on an alibi as their primary defense, claiming they were engaged in work unrelated to the incident at the time. They presented witnesses to corroborate this defense, but the trial court found their testimony less credible compared to the prosecution's evidence. The alibi defense was ultimately unsuccessful as the prosecution established the identity of the appellants as the perpetrators.
Judicial Decision on Guilt
On January 14, 1999, the Regional Trial Court found the appellants guilty beyond reasonable doubt of two counts of murder, imposing the death penalty for each count. The court ruled that the prosecution successfully proved the existence of conspiracy and the aggravating circumstances of treachery and evident premeditation. Notably, the court recognized the strategic manner in which the attack was carried out, which involved ambushing the victims from a concealed position, thus establishing treachery.
Subsequent Legal Proceedings and Appeals
The case then underwent automatic review under Article 47 of the Revised Penal Code. The appellants raised multiple assignment errors, contesting the credibility of the eyewitness, the appreciation of treachery and evident premeditation, and claiming the factors of "band" and "uninhabited place" as improper.
Analysis of Eyewitness Credibility
The court upheld the credibility of Adoracion Castro's testimony, rejecting claims that her view was obstructed by foliage and that her relationship to the victims biased her account. The trial court’s evaluation of her demeanor and the consistency of her testimony played a critical role in affirming her reliability as an eyewitness.
Establishment of Conspiracy
The court found sufficient evidence to substantiate a conspiracy among the appellants, identifying their simultaneous presence, shared weaponry, and coordinated actions during the assault on the victims. This collective conduct underscored their mutual intent to kill, thereby fulfilling the legal definition of conspiracy.
Treachery and Premeditation Assessment
Treachery was confirmed due to the calculated method of assault, ensuring the victims had no opportunity to defend themselves. However, the court found there was insufficient evidence of evident premeditation. The lack of explicit knowledge regarding when the pla
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Case Overview
- The case involves appellants Eufrocino Agudez y Asiong, Ronilo Agudez y Cocoy, and Ricardo Agudez y Cocoy, who were convicted of two counts of murder by the Regional Trial Court (RTC) of Kalibo, Aklan.
- The court sentenced each appellant to the death penalty for the murders of Dominador Castro and Mamerto C. Nalangan.
- The decision was rendered on January 14, 1999, and was subject to automatic review due to the imposition of the death penalty.
Facts of the Case
- On June 27, 1998, Dominador Castro and his nephew Mamerto Nalangan were shot while crossing the Jal-O river in Sitio Panukduka, Barangay Oquendo, Balete, Aklan.
- The prosecution established that the appellants, armed with shotguns, conspired to attack the victims with evident premeditation and treachery.
- Eyewitness Adoracion Castro testified to witnessing the shooting and identified the appellants as the assailants.
Charges
- The appellants were charged under two separate Informations for the crimes of murder, specifically in Criminal Cases Nos. 5176 and 5177.
- The accusations detailed the circumstances of the murders, including the use of firearms and the intent to kill.
Defense
- The appellants pleaded not guilty and presented an alibi as their defense, claiming they were not at the crime scene during the incident.
- They produced witnesses who testified to their whereabouts during the relevant time frame.
Prosecution Evidence
- The prosecution's case relied heavily on the testimony of Adoracion Castr