Case Summary (G.R. No. 86939)
Charges and Background
The Regional Trial Court (RTC) of Valenzuela, Metro Manila, received an Information against the accused on October 16, 1986. The Information alleged that Santos and Edgardo Ducay conspired to kill members of the Labos family using firearms, resulting in the deaths of Pacita and Manuel Labos, while also seriously injuring Lina, Edwin, and Ma. Cristina Labos. The accused entered a plea of not guilty during their arraignment.
Trial Process and Evidence
The prosecution presented several witnesses, including surviving members of the Labos family and police officers involved in the investigation. Key testimonies revealed that Santos Ducay and Edgardo Ducay entered the Labos residence early in the morning and opened fire. Lina Labos provided a detailed account of the attack, stating she recognized her attackers due to the light in the sala at the time of the incident.
Witness Edwin Labos corroborated Lina’s testimony by describing the attack and identifying both Santos and Edgardo as the assailants. Medical experts supported the prosecution's claims by discussing the injuries sustained by the victims and confirming that, without medical intervention, those injuries could have resulted in fatalities.
Defense Testimonies and Claims
The defense presented the Ducay family, who claimed they were at home during the attack. They argued that the identification by the witnesses was flawed and suggested an alibi. A neighbor of the Ducays and several other defense witnesses attempted to provide alternative versions of the events, asserting that the actual suspects did not match the descriptions of the Ducays.
Trial Court's Findings and Initial Judgment
On April 29, 1988, the trial court convicted Santos Ducay of double murder and multiple frustrated murder while acquitting Edgardo Ducay due to reasonable doubt. The court considered the evidence of conspiracy, premeditation, and the nature of the attack to impose a sentence of reclusion perpetua on Santos Ducay, alongside monetary indemnities for the victims' heirs.
Appellate Contentions
Santos Ducay subsequently appealed the trial court's decision, raising several errors in the court's evaluation of witness credibility and the rejection of evidence related to a paraffin test that supposedly indicated he did not handle a firearm. The appellant also questioned the trial court's categorization of the crime as a complex one rather than addressing each victim's situation separately.
Supreme Court Ruling
Upon review, the Supreme Court affirmed the trial court's findings regarding Santos Ducay’s guilt based on the strong evidence presented, especially the positive identification by eyewitnesses. However, it acknowledged errors in the trial court's views regarding the complexity of the crimes charged, determining that separate acts resulted in distinct crimes for each victim.
Sentencing and Modifications
The Supreme Court r
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Case Background
- Santos Ducay and Edgardo Ducay, father and son, were charged with the complex crime of double murder and multiple frustrated murder.
- The Information was filed on October 16, 1986, in the Regional Trial Court (RTC) of Valenzuela, Metro Manila.
- The alleged crime occurred on October 12, 1986, targeting Pacita Labos, Manuel Labos, Lina Labos-Mojica, Edwin Labos, and Ma. Cristina Labos.
Allegations
- The accused allegedly attacked and shot the victims with a .45 caliber pistol and a shotgun.
- The attack was characterized by evident premeditation, abuse of superior strength, and treachery.
- The prosecution claimed that the actions of the accused caused the death of Pacita Labos and Manuel Labos, while serious injuries were inflicted on the other victims.
Proceedings and Testimonies
- Upon arraignment, both accused entered a plea of not guilty.
- The prosecution presented witnesses including Edwin Labos, Lina Labos, Sgt. Ponciano Casile, and several medical professionals.
- Key testimony from Lina Labos described the attack, identifying Santos and Edgardo Ducay as the assailants due to the fluorescent light in the sala.
- Edwin Labos corroborated his sister-in-law's account, detailing the sequence of events and injuries sustained by the family.
Medical Evidence
- Dr. Rodolfo Lizondra performed autopsies on the deceased, determining the causes of death as hemorrhages from gunshot wounds.
- Medical professionals testified that the timely medical attention