Case Summary (G.R. No. L-23202)
Factual Background
On August 20, 1963, an information for murder was filed in the Court of First Instance of Cagayan against the aforementioned defendants. It was alleged that they conspired to kill Rodolfo Paulino, which resulted in Paulino sustaining fatal gunshot wounds. Medical evidence indicated that the cause of death was hemorrhage due to a gunshot wound.
Legal Proceedings and Initial Verdict
After trial, the court acquitted Grevel Galindon due to a lack of evidence conclusively linking him to the crime, while the other defendants were found guilty and sentenced to reclusion perpetua, along with a monetary indemnity to the heirs of the victim. This led to an appeal by the convicted defendants.
Issues Presented on Appeal
The appellants challenged the trial court’s ruling, raising several issues: the identification of the shooters, the role of Carlito Cabiera and Vicente Cortes in the raid, the establishment of conspiracy, and the admissibility of Cresencio Elizaga's confession, which he argued was obtained under coercion.
Circumstances of the Crime
On the night of the incident, gunfire erupted from outside the house belonging to Antonio Singson, who was present with Paulino and others. Singson observed multiple attackers, specifically identifying Elizaga and his group, which corroborated their capture shortly after fleeing the scene by constabulary soldiers.
Confessions and Evidence
Cresencio Elizaga's confession became a focal point in this case, as it was used to establish the involvement of the defendants in the crime. Despite his later claims of coercion, the court found the confession to be voluntary based on corroborating evidence gathered by authorities, such as descriptions of events and the recovery of firearms from the river.
Establishing Identity and Conspiracy
While eyewitness accounts lacked definitive identification of all the attackers, the circumstances surrounding the capture of the appellants shortly after the crime, combined with their actions before and during the event, reinforced the narrative that implicated them. The court noted that the escape and armament of the group, alongside prior tensions between the parties, suggested conspiracy and intent.
Decision on Appeal
The appellate court upheld the lower court's findings, concluding that the circumstantial evidence presented was compelling enough to affirm the guilt of Romarico Elizaga, Cresencio Elizaga, Jaime de la Cruz, and Vicente Cortes for the murder of Rodolfo Paulino. In contrast, the appeal concluded that Venerando Tobias and Carlito Cabiera did not have sufficient evidence against them and thus s
...continue readingCase Syllabus (G.R. No. L-23202)
Introduction
- The case revolves around a murder charge filed against several defendants, including Romarico Elizaga and others, related to the death of Rodolfo Paulino.
- The incident occurred on June 26, 1963, and involved allegations of conspiracy, premeditation, and the use of firearms.
- The lower court convicted the defendants, leading to the appeal by the appellants.
Factual Background
- An information for murder was filed against the defendants in the Court of First Instance of Cagayan.
- The prosecution alleged that the defendants conspired to kill Rodolfo Paulino, which was supported by medical evidence indicating that Paulino died from a gunshot wound.
- The trial court acquitted one defendant, Grevel Galindon, due to lack of evidence against him, while the others were found guilty and sentenced to reclusion perpetua.
- The case was appealed by five of the accused after the trial court's decision.
Appeal and Assignments of Error
- The appellants raised several errors in the trial court's decision:
- Incorrect identification of the defendants as the shooters.
- Misjudgment of the participation of Carlito Cabiera and Vicente Cortes in the alleged raid.
- Insufficient evidence establishing the identity of the accused.
- Misinterpretation of conspiracy among the accused.
- Erroneous admission of Cresencio Elizaga's confession, claimed to be coerced.
Incident Description
- On the night of June 26, 1963, a group led by Antonio Singson was in his house when it came under gunfire.
- Singson observed six individuals shooting at his house from a distance of approximatel