Title
People vs. Cabal y Dumadag
Case
G.R. No. 116487
Decision Date
Dec 15, 1997
Nicomedes Salas was shot dead in 1989; Pitao and Cabal were convicted based on witness identification, circumstantial evidence, and inadmissible confessions. Alibis were rejected.

Case Summary (G.R. No. 116487)

Charges and Information Filed

On August 22, 1989, an information charging the accused with murder was officially filed before the Regional Trial Court of the 10th Judicial Region, Branch 1, Butuan City. The allegation was that the accused, acting in concert with the intent to kill and using unlicensed firearms, shot and killed Nicomedes Salas on August 5, 1989.

Victim and Events Leading to the Crime

Nicomedes Salas was attending a school party with his family before the incident. Witnesses, including his wife Leticia Salas and the family driver Rogelio Amora, recounted the attack on Salas. After hearing gunshots, Leticia observed her husband fall to the ground, and she followed by witnessing two men fleeing the scene, later identified as Pitao and Cabal.

Autopsy and Confirmation of Death

Dr. Reinerio Durano performed an autopsy on August 6, 1989, determining that Salas died from severe internal hemorrhage caused by two gunshot wounds. This forensic evidence substantiated the prosecution's claims regarding the cause and manner of death.

Arrest of the Accused

The police, acting on information received, located Cabal and Pitao in Barangay Sumilihon on August 8, 1989. They were taken in for questioning, where incriminating statements began to emerge, particularly from Cabal, who admitted involvement in Salas' murder and named Aringue as the mastermind.

Investigations and Confessions

Cabal and Aringue underwent police interrogation, wherein they provided confessions connected to the murder. The police employed various methods to capture their statements—though, significantly, both later claimed these confessions were not given voluntarily.

Defense and Alibi

During the trial, both Cabal and Pitao presented alibi defenses, contending they were elsewhere during the time of the murder. However, their lack of corroborating witnesses undermined the credibility of their claims, while witness testimonies affirmed their presence at the scene.

Trial Court Decision

The trial court issued a verdict on December 10, 1993, convicting Pitao and Cabal of murder, sentencing them to reclusion perpetua, while acquitting Aringue due to reasonable doubt. The court ordered substantial indemnities to the heirs of Nicomedes Salas for moral damages, actual damages, and attorney’s fees.

Appeal by the Accused

Cabal and Pitao appealed their conviction on the basis of claims of coercion in obtaining their confessions and errors in the trial court's weighing of evidence. They contended that their confessions were inadmissible and that the prosecution had not met the burden of proof for a conviction.

Appellate Court Findings

The appellate court affirmed the trial court's decision, highlighting that substantial evidence confirmed the identities

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