Case Summary (G.R. No. 183094)
Case Background and Charges
Reynaldo Barde and his brother Jimmy were charged under an Information dated August 13, 1999, for the complex crime of multiple murder and multiple frustrated murder. The charges arose from an incident on April 15, 1999, when a hand grenade (M26-A1 fragmentation grenade) was rolled and exploded inside an open dancing area in Sitio Santo NiAo, Liguan, Rapu-Rapu, Albay. The explosion caused the instantaneous death of 15 persons and injuries to at least 76 others, including Purisima and Ligaya Dado, who survived but suffered injuries. The accused allegedly conspired and acted in concert in committing the crime with qualifying circumstances of treachery, evident premeditation, and use of explosion as a mode of killing.
Trial Court and Court of Appeals Decisions
The Regional Trial Court (RTC) found Reynaldo Barde guilty beyond reasonable doubt of the complex crime of multiple murder with multiple frustrated murder and sentenced him to reclusion perpetua. The RTC awarded damages to the heirs of the deceased and to the surviving injured victims. His brother Jimmy was acquitted due to insufficient evidence and failure to prove conspiracy.
The Court of Appeals (CA), affirming the RTC decision with modifications, increased the penalty from reclusion perpetua to death for the crime of murder. However, following Republic Act No. 9346, which abolished the death penalty, the penalty was reduced back to reclusion perpetua. The CA also increased the amounts awarded as moral, temperate, and exemplary damages to both the deceased victims’ heirs and surviving victims.
Facts Established by the Prosecution
Prosecution witnesses, including Elmer Oloroso (a first cousin of the accused) and Antonio Barcelona, testified that they witnessed the accused’s acts prior to and during the explosion. Both positively identified Reynaldo Barde as the individual who entered the dancing place, retrieved a hand grenade from his belt bag, rolled it towards the crowd of dancers, and left the area immediately before the explosion occurred. The testimony was corroborated by other witnesses and experts, including members of the Philippine National Police Explosive Ordnance Disposal Unit, who confirmed the use of an M26-A1 fragmentation grenade through forensic examination of shrapnels recovered at the scene.
Defense’s Version and Testimonies
The defense denied the accusations, offering an alibi version that Reynaldo Barde was organizing utensils and attending to family affairs outside the dancing place during the time of the explosion. They claimed that Reynaldo and his brothers were outside or at the far end of the dancing area when the grenade exploded. The defense further alleged coercion and torture during the investigation and claimed the court witness identification was unreliable. Testimony from a witness named Violeta Buemia attempted to implicate a third party named Eddie Oloroso, alleging he was the actual culprit, but this testimony was significantly delayed and lacked credibility.
Supreme Court’s Findings on Credibility and Evidence
The Supreme Court accorded respect and weight to the trial court’s and appellate court’s factual findings, particularly regarding witness credibility. It emphasized that the trial court, having observed the demeanor of witnesses, is best positioned to determine the truthfulness of testimonies. The Court upheld the positive identification of Reynaldo Barde by prosecution witnesses Elmer and Antonio, noting the well-lit environment, the witnesses’ familiarity with the accused, and the absence of any indication that the witnesses were motivated to falsely accuse the accused.
The Court rejected the defense’s alibi and denial as inherently weak and unsubstantiated. It found the delayed testimony of the witness Violeta as inconsistent and unconvincing, noting that fear did not justify her long delay in testifying. Minor inconsistencies in Elmer’s recounting of the timing of the explosion and Barde’s departure were clarified during cross-examination and considered insufficient to impair his credibility.
Legal Analysis on Crimes Committed
The Court ruled that the acts of the accused constituted the complex crime of multiple murder with double attempted murder. Fifteen victims died as a direct result of the grenade explosion, fulfilling the elements of murder under Article 248 of the Revised Penal Code, with qualifying circumstances of treachery and use of explosives. Treachery was found because the attack was sudden, unexpected, and without warning, leaving the victims no chance to defend themselves or escape, while the use of explosive was considered the principal qualifying circumstance.
For the injured survivors Purisima and Ligaya Dado, the Court held that their injuries were not fatal or mortal, and thus the crime committed against them was attempted murder rather than frustrated murder. This was because the prosecution failed to adequately prove that other injured victims’ wounds were fatal or that those victims would have died but for timely medical assistance. Furthermore, medical certificates for other injured victims were not formally offered as evidence, precluding the finding of frustrated murder in their cases.
Penalty Determination
As provided by Article 48 of the Revised Penal Code, when a single act constitutes two or more grave felonies, the penalty for the most serious crime shall be im
...continue readingCase Syllabus (G.R. No. 183094)
Case Background and Procedural History
- Appellant Reynaldo Barde and his brother Jimmy Barde were charged with the complex crime of multiple murder with multiple frustrated murder for detonating a hand grenade at a dance held in Sitio Sto. NiAo, Barangay Liguan, Rapu-Rapu, Albay, on April 15, 1999.
- The explosion instantly killed 15 persons and injured at least 76 others.
- The Regional Trial Court (RTC) of Legazpi City convicted appellant Reynaldo Barde guilty beyond reasonable doubt of the complex crime of multiple murder with multiple frustrated murder and sentenced him to reclusion perpetua.
- Appellant's brother, Jimmy Barde, was acquitted due to failure of the prosecution to prove conspiracy and insufficient evidence.
- The Court of Appeals (CA affirmed the RTC decision with modifications: the penalty for appellant was increased to death but reduced to reclusion perpetua pursuant to Republic Act No. 9346, which abolished the death penalty. The CA increased damages awarded to the victims' heirs and surviving victims.
- Appellant elevated the case to the Supreme Court, reiterating the argument that his guilt was not proven beyond reasonable doubt due to alleged inconsistencies and credibility issues with prosecution witnesses.
Facts of the Case
- On the evening of April 14, 1999, a feast-day dance was held in a well-lighted bamboo-enclosed area in Sitio Sto. NiAo.
- Prosecution witnesses Elmer Oloroso (appellant’s first cousin) and Antonio Barcelona testified they saw appellant enter the dancing area with a hand grenade, roll it towards the crowd, then swiftly leave before the grenade exploded.
- The explosion caused chaos, resulting in 15 immediate fatalities and multiple injuries.
- Investigations by the Philippine National Police's Explosive and Ordinance Disposal team confirmed the explosive device was an M26-A1 fragmentation grenade.
- Other prosecution witnesses corroborated the incident's description and appellant's involvement.
- Defense witnesses, including appellant himself, denied appellant’s involvement, claiming he was outside or distant at the time of the explosion, engaged in conversation, or did not throw the grenade.
- Violeta Buemia, a late witness who testified more than two years later, claimed to have seen another individual, Eddie Oloroso, throw an object that caused the explosion.
- Appellant and Jimmy also alleged coercion and torture by authorities to force confessions.
- The defense denied the prosecution’s identification and suggested mistaken identity or conspiracy against the appellant.
Issues Presented
- Whether the prosecution proved appellant Reynaldo Barde's guilt beyond reasonable doubt in rolling and detonating the grenade.
- Whether appellant's defense of denial and alibi sufficed to overcome the positive identification by prosecution witnesses.
- What is the legally appropriate criminal charge and penalty given the facts.
- Appropriate damages payable to deceased victims' heirs and surviving injured victims.
Court's Ruling on Guilt Beyond Reasonable Doubt
- The Supreme Court affirmed the trial court and Court of Appeals factual findings, giving high respect to the trial court’s opportunity to observe witnesses and assess credibility.
- Prosecution witnesses Elmer and Antonio gave clear, spontaneous, and consistent testimonies po