Title
People vs. Brioso
Case
G.R. No. L-28482
Decision Date
Jan 30, 1971
Juan Brioso and Mariano Taeza conspired to murder Silvino Daria in Tayum, Abra, on December 23, 1966, motivated by a rejected courtship. Witnesses identified the accused; alibi defenses were rejected. The Supreme Court upheld their conviction for murder, increasing indemnity to the heirs.

Case Summary (G.R. No. L-28482)

Charges and Initial Proceedings

An information filed by the Provincial Fiscal on January 16, 1967, charged Brioso and Taeza with murder under Article 248 of the Revised Penal Code. The prosecution contended that the accused, armed with firearms, conspired to kill Silvino Daria with treachery and evident premeditation. Following the shooting, Daria succumbed to multiple gunshot wounds inflicted by the accused.

Evidence Presented

Eyewitness Cecilia Bernal testified that she saw the two appellants approach and shoot at Daria’s house. Following the shooting, the victim managed to inform his wife that he had been shot by Brioso and Taeza. Bernal's account was corroborated by the findings of the health officer, who stated the cause of death as "shock due to severe hemorrhage secondary to gunshot wounds."

Defense and Appeal

The defendants appealed the trial court's decision, arguing errors regarding witness credibility and alibi. They contested the reliability of Bernal’s testimony and presented an affidavit from Antonio Daria, claiming it exonerated Taeza. The judgment of the trial court hinged on the credibility of eyewitnesses and whether the alleged alibi could be substantiated.

Assessment of Witness Credibility

The court noted no material discrepancies in Bernal’s testimony, asserting that her identification of the defendants was credible despite some inconsistencies. The trial judge observed Bernal closely and found her straightforward and truthful. This led the court to give her testimony full weight, especially as it aligned with the victim's dying declaration.

Defense of Alibi

Mariano Taeza's alibi claimed he was several meters away at a barrio clinic playing the guitar when the shooting occurred. However, this alibi lacked corroboration from any witnesses present at the clinic. The court established that their proximity to Daria's residence made it plausible for them to have been present during the shooting, undermining the defense of alibi.

Findings on the Nature of the Crime

The court concluded that the murder was characterized by treachery, given that the victim was caught off guard in his own home, thus having no opportunity to defend himself. This exacerbated the gravity of the crime under the Revised Penal Code, qualifying it for the imposition of a heavier penalty.

Sentencing

The trial court originally sentenced the defendants to life impri

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