Case Summary (G.R. No. 102596)
Facts of the Case
The facts are not in dispute and are based on the findings of the Regional Trial Court. On July 2, 1987, around 4:30 PM, while Insular and his wife were walking home from the market, they encountered Yolly Armada, who was armed. After a brief interaction, Armada shot Insular, prompting several others, including the accused-appellants, to join in the assault with their firearms. Insular was hit multiple times before the group attempted to turn the scene to create a justification for the shooting. The accused allegedly kept Insular's wife and a bystander captive nearby to suppress any immediate reporting to authorities.
Indictment and Trial Proceedings
On March 11, 1988, the Provincial Fiscal filed an Information for murder against the appellants. During the trial, eyewitness accounts were presented, including testimony from the victim's wife and a bystander, which corroborated the sequence of events and the actions of the appellants. The prosecution described how Insular suffered multiple gunshot wounds leading to his death, establishing a clear cause of death as attributable to the assault.
Defense Arguments
The defense presented alibi and denial as key arguments. They contended that they were not at the crime scene and offered contradictory evidence to assert their innocence. Yolly Armada claimed self-defense, arguing that he acted in response to a perceived threat from Insular. However, testimonies from witnesses and the recovered evidence did not support their claims, and the trial court deemed the self-defense claim implausible.
Decision of the Trial Court
On October 31, 1990, the trial court found the accused-appellants guilty of murder. The court held that conspiracy among the appellants was established, recognizing that their collective actions indicated a common design to kill Insular. Furthermore, the court rejected the claim of self-defense and concluded that the killing was committed with treachery and abuse of superior strength, warranting the penalties imposed.
Appeals and Judicial Review
The appellants appealed, raising several errors, especially concerning the trial court's findings on conspiracy and treachery. While some co-accused escaped or failed to appeal, the case continued for Nicasio Enoja and Ronnie Enoja. The appellate court upheld the trial court's conclusions, affirming the guilty verdict based on the overwhelming evidence indicating a coordinated attack on Insular.
Sentencing
Nicasio Eno
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Case Overview
- This case involves an appeal from the decision dated October 31, 1990, of the Regional Trial Court in Iloilo City, which convicted the accused-appellants of murder.
- The primary accused are Nicasio Enoja @ "Nick", Jose Enoja @ "Moros", Antonio Galupar @ "Tony", Ronnie Enoja @ "Bud-oy", and Yolly Armada.
- The crime pertains to the murder of Siegfred G. Insular, who was shot under circumstances indicating conspiracy among the accused.
Background of the Case
- The incident occurred on July 2, 1987, in Barangay Caraudan, Janiuay, Iloilo.
- The victim, Siegfred G. Insular, was a suspected commander of the New People’s Army (NPA).
- Prior to the incident, there were violent confrontations involving the Enoja family, including the shooting of Romulo Enoja's daughter and son, and the burning of their mother's house by the NPA.
Incident Details
- On the day of the incident, Siegfred Insular and his wife, Paterna, encountered Yolly Armada, who was armed, while walking home.
- After a brief interaction, Yolly Armada shot Siegfred, and he was subsequently attacked by other armed men, identified as the co-accused, who took turns shooting him.
- Paterna Insular attempted to intervene but was spared from violence due to the intercession of a bystander, Teodoro Salamanca.
Legal Proceedings
- The Provincial Fiscal filed an Information for murder against the accused on March 11, 1988.
- The accused were arraigned on August 5, 1988, and all pleaded not guilty.
- An ar