Case Summary (G.R. No. 132676)
Key Dates
Incident: August 25, 1996 (approx. 8:00 PM)
Witness’s Formal Statement: September 4, 1996
Criminal Complaint Filed: October 3, 1996
Arrests: Jaime Carpo (October 25, 1996), Roche Ibao (December 9, 1996), Oscar and Warlito Ibao (surrendered December 1996)
Trial: 1997–1998
Decision: April 4, 2001 (En Banc, Supreme Court)
Applicable Law
• 1987 Philippine Constitution (post–1990 decision)
• Revised Penal Code, Article 48 (complex crimes)
• Republic Act No. 7659 (death penalty statute)
• Civil Code, Article 1878 (attorney’s power to compromise)
• Rules of Court, Rule 138, Section 23 (attorney’s authority)
Factual Background
On the evening of August 25, 1996, Ruben Meriales, prompted by his mother’s concern over their cow, concealed himself behind his kitchen washbasin. He observed Barangay Captain Jaime Carpo and Warlito Ibao near his barn, Roche Ibao by the mango tree, and Oscar Ibao approach the Dulay residence. Oscar lifted a sawali mat, hurled an object inside, and fled toward a creek with Roche. A grenade explosion followed, killing Florentino, Norwela, and five-year-old Nissan Dulay, and wounding Noemi Dulay. Ruben obtained transport for the injured, but Norwela and Nissan succumbed en route or upon arrival at the hospital.
Investigation and Criminal Complaint
Fearful of retaliation, Ruben delayed giving his statement until September 4, 1996. He identified the four accused as perpetrators, alleging the motive was to silence Florentino, who was to testify against Roche for his brother’s murder. On October 3, 1996, the Municipal Circuit Trial Court issued arrest warrants based solely on Ruben’s testimony.
Trial Proceedings and Evidence
Prosecution witnesses included Ruben Meriales, the surviving victim Noemi Dulay, two physicians, and responding police officers. Investigators recovered grenade fragments, a grenade shifting lever, and obtained statements from Teresita Dulay (widow of Florentino) and Ruben identifying the accused. The defense presented alibi testimony from the accused and their relatives, challenged Ruben’s credibility as harboring a grudge, and offered lie-detector results.
Defense Alibi and Motive Allegations
Jaime Carpo and wife testified he was 150 meters away in Barangay Libsong when the blast occurred and that crossing a deep creek would have delayed him at least thirty minutes. The Ibaos claimed attendance at a farewell party, denied hearing police calls, and asserted Roche did not reside near the crime scene. They characterized Ruben’s testimony as retaliatory for Roche’s alleged involvement in his brother’s death.
Trial Court Findings on Credibility
The trial court rejected the defense alibis and credited Ruben’s “straightforward testimony” as unimpeached and consistent. It found his fear explainable, held the lie-detector evidence inadmissible, and deemed the accused’s conduct (flight, tarriance, lack of inquiry after the blast) indicative of guilt.
Supreme Court’s Assessment of Witness Credibility
The Supreme Court accorded deference to the trial court’s findings, ruled Ruben’s affidavit and testimony substantially consistent, and held any minor discrepancies immaterial. It found the admitted resentment against the Ibaos did not invalidate his account and deemed defense claims of jailhouse admission unsupported.
Conspiracy and Complex Crime
Relying on Ruben’s detailed narrative, the Court affirmed that the accused conspired: Jaime and Warlito positioned themselves to encourage Oscar, the principal assailant, with Roche as look-out. Under Article 48, the grenade explosion giving rise to three deaths and one wounding constituted a complex crime of multiple murder with attempted murder.
Penalty Imposed
In conformity with Article 48 and Section 6 of RA 7659, the Supreme Court affirmed the penalty of death (supreme penalty in its maximum) for each accused. Th
Case Syllabus (G.R. No. 132676)
Facts of the Crime
- On 25 August 1996 at about 8:00 PM, Ruben Meriales was at home in Brgy. Baligayan, Pangasinan, watching television when his dogs barked.
- His mother, fearing cow theft, urged him to inspect; Ruben took a flashlight and walked along an unpaved path to the mango‐tree where the cow was tied.
- Having moved the cow nearer the house, he hid behind bamboo slats atop a concrete washbasin in the kitchen to observe by the light of two electric bulbs (3 m away) and moonlight.
- He saw Barangay Captain Jaime Carpo and Warlito Ibao stooping near his hay barn; Roche Ibao stood by the mango tree; Oscar Ibao approached Florentino Dulay’s hut.
- Oscar lifted the sawali mat near the wall, hurled an object inside (later identified as a grenade), then fled toward a nearby creek followed by Roche.
- Seconds later, a grenade explosion rocked the neighborhood; Teresita Dulay’s screams pierced the night.
- Ruben ran home for his flashlight, returned to aid Teresita, and found Florentino cradled by his widow Norwela, both Nissan (5 years old) and Norwela fatally wounded on a cot, and Noemi motionless with a head wound.
- He borrowed a jeepney from Brgy. Kagawad Edgardo Marquez to rush victims to Eastern Pangasinan District Hospital.
- Norwela died en route; Nissan died later from “shock from pains” due to shrapnel wounds; Noemi survived but was transferred to Dagupan City for lack of facilities.
- Ruben initially refused to give a statement out of fear; on 4 September 1996, after the burial, he executed an affidavit naming Jaime Carpo, Warlito, Oscar and Roche Ibao as perpetrators and stating the motive: Florentino was about to testify against Roche in the murder of Ruben’s brother, Delfin Meriales.
Police Investigation and Criminal Complaint
- On 25 August 1996, Police Officer Guillermo Osio and colleagues responded to the scene, collected grenade shrapnels and a grenade shifting lever.
- Conversations with Teresita Dulay and Ruben Meriales led to preliminary identification of suspects; Ruben promised a formal statement after funeral.
- On 3 October 1996, based solely on Ruben’s affidavit, a criminal complaint for murder (Florentino, Norwela, Nissan) and frustrated murder (Noemi) was filed before the Tayug, Pangasinan RTC.
- Warrants for the arrest of Jaime Carpo, Warlito Ibao, Oscar Ibao and Roche Ibao issued immediately.
- Arrest timeline: Jaime Carpo on 25 October 1996; Roche Ibao evaded until 9 December 1996; Oscar and Warlito Ibao surrendered thereafter to the NBI in La Union.
Trial Proceedings
- Prosecution witnesses: Ruben Meriales, Noemi Dulay, Dr. Rosalina O. Victorio, Dr. Emiliano Subido, POs Virgilio dela Cruz, Jovencio Tapac and Guillermo Osio.
- PO Osio testified on evidence gathering, interviews with witnesses, and visits to suspects’ houses (locked and unoccupied).
- Defense witnesses: Jai