Case Summary (G.R. No. L-61408)
Charges and Sentencing
The defendants were charged with murder under Criminal Case No. 412. The trial court sentenced Isidro, Edmundo, and Gavino Clores to reclusion perpetua, ordered them to indemnify the heirs of Victorio Barcarse, Jr. in the amount of P12,000.00, and required them to pay the costs of the trial. Cynthia Clores, the daughter, was acquitted due to a lack of evidence.
Background of the Incident
On April 11, 1970, representatives from the Barcarse family, including Felisa Barcarse and her son Victorio, visited Isidro Clores's home to discuss the potential marriage of Victorio and Isidro's daughter Salome. After an inconclusive preliminary discussion, Cynthia Clores fetched Victorio on April 24, 1970, for further discussions, but he did not return home. His mother, Felisa, later reported his disappearance and suspected foul play after discovering a body wrapped in a sack.
Investigation and Eyewitness Testimony
The initial investigation, led by Philippine Constabulary Investigator Eustaquio Mellilin, failed to yield useful evidence. However, in June 1975, after an eyewitness named Morel Callueng came forward, the case was revived. Callueng alleged that he witnessed the murder. He claimed to have seen Gavino sitting on top of Victorio, gagging him while Edmundo struck him repeatedly with a rifle butt. Isidro was purportedly present, encouraging Edmundo to complete the act.
Defense Claims
The defendants presented a defense based on denial and alibi, asserting their absence during the incident. Edmundo claimed he was in Quezon City at the time, Isidro testified he was ill in Manila, and Gavino maintained he was at his workplace. The appellants argued that their familial ties to Victorio negated any motive for murder.
Trial Court's Rationale
The trial court accepted Callueng's testimony, emphasizing its consistency and clarity. It found that the positive identification of the defendants outweighed their alibis. The court dismissed the defense's claims regarding political motivations behind the charges as inconsequential, prioritizing the eyewitness identification.
Appeal and Solicitor General's Position
In the subsequent appeal, the Solicitor General recommended that the conviction be overturned, citing significant inconsistencies and concerns regarding the credibility of Callueng. The Solicitor General highlighted discrepancies in Callueng’s testimony, including confusion about how he arrived at the scene and what he actually witnessed, arguing that these inconsistencies undermined the reliability of his account.
Presumption of Innocence and Weakness of Prosecution's Case
The appellate court emphasized the presumption of innocence, s
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Case Overview
- The case involves Isidro Clores and his two sons, Edmundo and Gavino, who were charged with the murder of Victorio Barcarse, Jr. in Criminal Case No. 412 in the Circuit Criminal Court of Tuguegarao, Cagayan.
- The trial court found them guilty and sentenced them to reclusion perpetua, requiring them to indemnify the victim's heirs and pay costs.
- A fourth defendant, Cynthia Clores, was acquitted due to lack of evidence.
- The defendants appealed the trial court's decision.
Background of the Incident
- On April 11, 1970, Felisa Barcarse and her son Victorio visited Isidro Clores to discuss a marriage proposal for his daughter, Salome.
- On April 24, 1970, Cynthia Clores fetched Victorio from the Barcarse household for further marriage discussions.
- Victorio did not return home that evening, prompting Felisa to inquire about his whereabouts with Isidro, who feigned ignorance.
- A dead body, later identified as Victorio, was discovered days later, leading to an investigation by the Philippine Constabulary.
Investigation and Witness Testimony
- The investigation initially yielded no suspects, but in June 1975, the case was revived when an eyewitness, Morel Callueng, claimed to have seen the murder.
- Callueng testified that he observed Gavino Clores restraining Victorio while Edmundo assaulted him with a rifle.
- Isidro was allegedly present, instructing his sons to