Case Summary (G.R. No. 247906)
Charges and Criminal Cases
Three separate informations were filed against the accused-appellants for the following:
- Criminal Case No. 4810 – Murder of Emerita Roma, qualified by treachery and evident premeditation.
- Criminal Case No. 4811 – Murder of Ireneo Gallarte, qualified by treachery and evident premeditation.
- Criminal Case No. 4812 – Attempted murder of Flor Espinas.
The accused were charged with employing treacherous means, armed with a .38 caliber handgun, and acting in conspiracy.
Trial Court Decision and Sentences
The Regional Trial Court found Hermogenes and Edwin Flora guilty beyond reasonable doubt of:
- Murder of Emerita Roma and Ireneo Gallarte, sentencing them to reclusion perpetua with corresponding indemnities for death, burial expenses, and loss of earning capacity.
- Attempted murder of Flor Espinas, sentencing them to an indeterminate penalty of imprisonment and indemnity payment.
Factual Background and Incident Description
The incident occurred during a dance party celebrating a birthday in Sitio Silab, Barangay Longos, Kalayaan, Laguna, at approximately 1:30 a.m. on January 10, 1993. Hermogenes and Edwin Flora attended the party. Upon a signal from Edwin, Hermogenes fired his gun twice, hitting Emerita Roma and Ireneo Gallarte fatally, and Flor Espinas severely but not fatally. Edwin threatened a witness, Rosalie Roma, before they fled.
Arrest and Forensics
Edwin Flora was arrested early morning in Barangay Bagumbayan, Paete, Laguna, while Hermogenes fled to Camarines Sur later that day. Autopsy reports confirmed the fatal gunshot wounds and cause of death due to massive blood loss. Medical examination of Flor Espinas showed serious gunshot wounds that would have been fatal but were mitigated by timely medical treatment.
Eyewitness Testimonies and Defense
Two primary eyewitnesses, Rosalie Roma and Flor Espinas, positively identified Hermogenes and Edwin Flora as perpetrators. The defense presented alibi testimonies from the accused and Edwin's common-law wife, claiming the accused were elsewhere at the time of the shooting.
Analysis of Alibi and Identification
The trial court rejected the alibi defense for failure to establish physical impossibility to be present at the crime scene. The court emphasized that alibis, often self-serving and uncorroborated by disinterested witnesses, are disfavored in law. The mere proximity of the sisters’ house to the crime scene (approximately one kilometer) was insufficient to prove absence.
Credibility of Witnesses and Minor Inconsistencies
The court recognized the positive identification by eyewitnesses despite minor inconsistencies in testimony. Such inconsistencies, pertaining to non-material details, do not discredit witness credibility but may strengthen it by negating possibility of memorized falsehoods. The proximity of the witnesses to the event and the accused was sufficient to establish reliable identification.
Absence of Proven Bias or Ulterior Motive
Although relatives of one victim, the witnesses displayed no proven improper motive or bias against the accused. The court underscored that relationship to the victim does not negate truthful testimony absent proof of malicious intent.
Criminal Liability of Hermogenes Flora
Hermogenes Flora was found criminally liable for the murders and attempted murder. Under the doctrine of aberratio ictus, liability attaches notwithstanding unintended injuries to persons other than the intended target. The qualification of treachery was established through the method of execution designed to prevent defense or retaliation by the victims.
Criminal Liability of Edwin Flora and Conspiracy
Edwin Flora’s liability derived from conspiracy with Hermogenes Flora to commit murder, although only specifically for the murder of Ireneo Gallarte. Conspiracy was evidenced by Edwin’s acts—such as signaling Hermogenes to shoot and threatening a witness—which demonstrated unity of purpose and concerted execution. Edwin, however, was acquitted for the murder of Emerita Roma and the attempted murder of Flor Espinas as the evidence showed no conspiracy regarding those acts.
Legal Principles on Conspiracy and Liability for Acts Beyond Conspiracy
Under Philippine jurisprudence, co-conspirators are liable only for acts done pursuant to the conspiracy or those which are necessary and logical consequ
Case Syllabus (G.R. No. 247906)
Background and Procedural History
- This case concerns the appeal filed by Hermogenes Flora and Edwin Flora, convicted of double murder and attempted murder by the Regional Trial Court (RTC), Branch 26, Santa Cruz, Laguna, in Criminal Case Nos. SC-4810, 4811, and 4812.
- The RTC decision dated November 7, 1995, found both appellants guilty beyond reasonable doubt and imposed the penalty of reclusion perpetua for the murders and imprisonment ranging from prision correccional to prision mayor for the attempted murder.
- The appellants were also ordered to pay indemnities for death, burial expenses, loss of earning capacity, and indemnity for injuries sustained.
- Appeals were made based on alleged failure of the prosecution to morally ascertain their identities and guilt.
Facts of the Case
- On the night of January 9, 1993, a dance party was held in Sitio Silab, Barangay Longos, Kalayaan, Laguna where the victims Emerita Roma, her daughter Rosalie Roma, Flor Espinas, and a neighbor, Ireneo Gallarte, were present.
- Hermogenes Flora and his brother Edwin Flora attended; Hermogenes was an alleged suitor of the celebrant.
- Around 1:30 AM on January 10, 1993, Edwin signaled Hermogenes who fired two shots using a .38 caliber revolver.
- The first gunshot grazed Flor Espinas and hit Emerita Roma, the second shot hit Ireneo Gallarte, who later died.
- Edwin threatened Rosalie Roma with a knife as they fled, leaving the victims critically wounded or dead.
- The victims were taken to a rural health unit where Emerita Roma and Ireneo Gallarte were pronounced dead.
Criminal Informations and Charges
- Three separate informations were filed charging both accused with:
- SC-4810: Murder of Emerita Roma by treachery and evident premeditation.
- SC-4811: Murder of Ireneo Gallarte qualified by treachery and evident premeditation.
- SC-4812: Attempted murder of Flor Espinas, including elements of treachery and evident premeditation.
- All charges outlined the use of a firearm with intent to kill, and conspiratorial participation by both accused.
Trial Proceedings and Evidence
- Both accused pleaded not guilty during arraignment.
- Prosecution presented eyewitnesses Rosalie Roma and Flor Espinas who identified the accused as perpetrators.
- Medical evidence:
- Autopsy revealed fatal gunshot wounds to Emerita Roma and Ireneo Gallarte consistent with the described incidents.
- Flor Espinas sustained serious gunshot injuries but survived due to timely medical intervention.
- Testimony from the victims' relatives established economic loss and burial expenses.
- Defense raised alibi, claiming appe