Title
People vs. Fieldad
Case
G.R. No. 196005
Decision Date
Oct 1, 2014
Appellants convicted of murdering jail guards and carnapping in 1999; conspiracy, treachery, and discernment established; penalties and damages modified.
murder
carnapping
witness identification

Case Summary (G.R. No. 196005)

Factual Background

On the morning of March 9, 1999, at the Bureau of Jail Management and Penology compound in Brgy. Anonas, Urdaneta City, jail officers JO2 Reynaldo Gamboa, JO1 Juan Bacolor, Jr., and JO2 Marlon Niturada were at the nipa hut conducting routine activities when inmates allegedly conspired to attack them. Witness testimony established that Julius Chan approached JO2 Gamboa and shot him; contemporaneously, Charlie Fieldad and Ryan Cornista grappled with JO1 Bacolor for possession of an armalite, Cornista struck Bacolor in the head, and Fieldad used Gamboa’s gun to shoot Bacolor. Another inmate, Florante Leal, fired at JO2 Niturada, who returned fire. The assailants then used keys taken from JO2 Gamboa to open the main gate and effected an escape. Several inmates boarded a parked Tamaraw jeep, Plate No. CDY-255, belonging to Benjamin Bauzon without his consent, later transferred to a Mazda pick-up which overturned in San Miguel, Tarlac, and the fugitives were arrested in a nearby cane field. Autopsies performed by Dr. Constante Parayno and Dr. Ramon Gonzales, Jr. respectively concluded that JO1 Bacolor died from hemorrhage due to a gunshot wound of the right lung and JO2 Gamboa died from cardiac tamponade due to a gunshot wound.

Criminal Information and Charges

Three Informations were filed. In Criminal Case No. U-10053 the accused, including Charlie Fieldad, were charged with murder with the use of an unlicensed firearm for the killing of JO2 Reynaldo Gamboa, contrary to Article 248, Revised Penal Code, as amended. In Criminal Case No. U-10054 similar charges were filed for the killing of JO1 Juan Bacolor, Jr. In Criminal Case No. U-10055 six accused, including Charlie Fieldad and Edgar Pimentel, were charged with carnapping of a Tamaraw jeep, contrary to R.A. 6539. Upon arraignment, the accused pleaded not guilty.

Prosecution Evidence

The prosecution presented multiple jail officers, medical examiners, police officers, the vehicle owner, and civilian witnesses. Witness Dionisio Badua positively identified Charlie Fieldad and Ryan Cornista and recounted in detail their grappling for Bacolor’s armalite, Cornista’s blow to Bacolor’s head, and Fieldad’s appropriation of Gamboa’s firearm and the subsequent shootings. JO2 Niturada and other jail personnel testified to seeing the accused in confederation by the nipa hut before the shootings. Forensic evidence included paraffin casts taken from Fieldad and a report by forensic chemist Theresa Ann Bugayong‑Cid that the paraffin test of Fieldad’s hands was positive for gunpowder nitrates. Autopsy reports corroborated a close‑range shooting and signs of a struggle. The owner of the Tamaraw jeep, Benjamin Bauzon, testified that his vehicle was missing from its parking place and that he found it later at Bactad, supporting lack of consent.

Defense Evidence and Testimonies

The accused offered accounts asserting lack of criminal intent and coercion. Charlie Fieldad testified that he was ordered at gunpoint by Florante Leal to drive the Tamaraw jeep and that he took cover and fled during the exchange of gunfire, asserting fear and a degree of involuntary participation. Edgar Pimentel described having been threatened by Leal with an armalite and moving stones and boarding the jeep under compulsion. Ryan Cornista testified that he was a minor, that he hid in the jeep out of fear and was threatened by Leal. Each accused denied participatory guilt in the killings and asserted duress or lack of knowledge as to the criminal plan.

Trial Court Ruling

The Regional Trial Court found Julius Chan, Charlie Fieldad, and Ryan Cornista guilty beyond reasonable doubt of murder in Criminal Case Nos. U-10053 and U-10054 and sentenced each to reclusion perpetua, and ordered awards of civil indemnity, moral damages, exemplary damages, actual funeral expenses and loss of earning capacity to the heirs. The trial court acquitted several co‑accused for lack of proof. In Criminal Case No. U-10055 the trial court convicted Charlie Fieldad, Edgar Pimentel, and Ryan Cornista of carnapping and imposed imprisonment from fourteen years and eight months to sixteen years and two months, and awarded nominal and moral damages to the vehicle owner. The trial court expressly found treachery as a qualifying circumstance in the homicides.

Issues on Appeal

Appellants raised four principal assignments of error: that the prosecution failed to prove guilt beyond reasonable doubt; that the trial court erred in finding conspiracy and treachery; that the trial court erred in failing to appreciate Cornista’s minority at the time of the offenses; and that the trial court disregarded the accused‑appellants’ testimonies and defenses, including duress and alibi.

Court of Appeals Ruling

The Court of Appeals affirmed the trial court’s judgments with a single modification: it reduced the penalties imposed on Ryan Cornista in the two murder cases in view of the privileged mitigating circumstance of minority, finding that Cornista nevertheless acted with discernment based on his participation in grappling for the armalite, striking Bacolor, and using the keys to open the main gate. Cornista later withdrew his appeal, rendering the judgment final and executory as to him. The Court of Appeals otherwise sustained the findings of conspiracy, treachery, and culpability of Fieldad and Pimentel in the respective convictions.

Supreme Court's Resolution

The Supreme Court dismissed the appeal of Charlie Fieldad and Edgar Pimentel and affirmed the Court of Appeals decision with modifications. The Court ordered that Fieldad be sentenced to reclusion perpetua without eligibility for parole under Republic Act No. 9346 for the murder convictions. The Court increased the exemplary damages in each murder case to PHP 30,000.00, corrected the trial court’s computation of loss of earning capacity by converting monthly to annual income and multiplied the awards accordingly—awarding PHP 1,836,336.00 to the heirs of JO2 Gamboa and PHP 2,142,000.00 to the heirs of JO1 Bacolor—and deleted the award of moral damages in the carnapping case for lack of proof of mental or physical suffering by the vehicle owner. The Court imposed interest at the legal rate of six percent per annum on all damages from finality of judgment until fully paid.

Legal Basis and Reasoning

The Court applied established principles. It affirmed treachery where the victim was defenseless at the time of attack and the assailants adopted means that insured the crime’s execution without risk to themselves, citing precedent such as People v. Escote, Jr. and People v. Tabaco. The Court found that the jail officers, though armed, were deprived of any opportunity to defend themselves by the sudden, concerted acts of the inmates. Identity and participation of Fieldad were supported by Badua’s positive identification and by a web of corroborative circumstantial evidence: eyewitness accounts placing Fieldad grappling for the armalite and seizing Gamboa’s gun, the autopsy findings indicating a struggle and close‑range shooting, paraffin casts and positive gunpowder residue reports, and admissions that Fieldad boarded and drove the jeep. The Court reiterated that paraffin testing and the taking of paraffin casts do not violate the privilege against self‑incrimination as the privilege extends only to testimonial compulsion, citing People v. Gamboa. The existence of conspiracy was inferred from the accused’s concerted actions and shared purpose; once conspiracy was shown, the act of one was imputed to all conspirators pursuant to Revised P

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