Title
People vs. Feliciano, Jr.
Case
G.R. No. 196735
Decision Date
May 5, 2014
Seven Sigma Rho fraternity members attacked by masked men at UP Diliman; one died. Accused Scintilla Juris members acquitted due to unreliable witness identification and delayed testimony.

Case Summary (G.R. No. 247906)

Sufficiency of the Information

Accused-appellants challenged inclusion of “wearing masks or other forms of disguise” as an aggravating circumstance, arguing it conflicted with evidence that masks fell off. The Court reaffirmed that every aggravating circumstance must be alleged in the information (Rules 110, Sec. 8). Disguise is an established aggravating factor akin to nighttime assault because it conceals identity. Alleging disguise fully apprised the accused; subsequent evidence that some masks fell off did not render the information insufficient or violate due process.

Credibility and Sufficiency of Identifications

Victims testified they positively identified certain attackers—Alvir, Zingapan, Medalla, Soliva, Feliciano—because their masks fell or were not worn. Defense witnesses and initial bystanders insisted all assailants remained masked. In weighing rapid-fire identifications, the Court observed:
• Minor inconsistencies in detail are natural and may even indicate spontaneity.
• Positive identification by victims who faced deadly blows and knew their fraternities’ members left an indelible impression.
• The trial court’s recognition that victims named only a few attackers—rather than indiscriminately finger all—bolstered credibility.
The SC held that the trial and appellate courts did not err in finding five respondents sufficiently identified beyond reasonable doubt.

Weight of Trial Court Findings and Exceptions

The trial court’s factual findings, especially on witness credibility, carry great weight on appeal under People v. Quijada. Exceptions arise when findings are arbitrary, biased, or devoid of basis. Here, 11 prosecution and 42 defense witnesses testified over six years; an 83-page decision acquitting six and convicting five demonstrates judicious evaluation. The SC saw no reason to disturb those findings, as they were not arbitrary or baseless.

Res Gestae Statements

Testimony by bystanders and UP police officers that none of the masked assailants were recognized qualifies as res gestae (Rule 130, Sec. 42). Although admissible, these declarations have limited persuasive value compared to victims’ firsthand accounts. The Court distinguished spontaneous res gestae utterances—denying recognition—from prepared identifications later made at the NBI.

Delayed Identification and Victim Statements

Victims initially told UP Police Officers Cabrera and Salvador, and Dr. Mislang at the UP Infirmary, that the assailants were unidentifiable due to masks. Four days later they executed NBI affidavits naming respondents. The SC held the delay did not automatically discredit their positive identification:
• Hospitalization and medical treatment justified postponement.
• Fraternity protocols and advice of senior brothers and counsel led victims to coordinate statements before the NBI.
• The NBI’s broader investigatory resources made it a preferred forum over campus security police.

Alibi and Denial Do Not Prevail

Respondents’ alibis—being in Pampanga, at SM North, eating elsewhere—were corroborated by family, friends, and co-workers. Nonetheless, the SC reaffirmed the doctrine that alibi and denial, being self-serving and easily fabricated, cannot overcome positive identification by credible crime victims. No alibi evidence was clear and convincing to raise reasonable doubt.

Aggravating Circumstance of Treachery and Conspiracy

Murder under Article 248, RPC, requires

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