Case Summary (G.R. No. 111009-12)
Applicable Law
The incidents in question occurred in June 1992, and the decision is based on the provisions of the 1987 Philippine Constitution as the effective legal framework at the time of adjudication. The charges fell under the Revised Penal Code regarding murder and attempted murder.
Summary of Facts
The accusations stemmed from events occurring between June 18 and 19, 1992, along Naguilian Road, Municipality of Sablan, Benguet, where the accused allegedly conspired to abduct and subsequently murder the four women. The modus operandi involved using police vehicles to transport the victims to a remote location where they were attacked. Myrna Diones survived and provided critical testimony regarding the events leading to the murders.
Trial Court Proceedings
During the trial, all accused pleaded not guilty. The trial court found compelling evidence against the accused primarily through the testimony of Myrna Diones. Myrna described how she and the other victims were taken by the accused under the pretense of being apprehended for theft. She recounted being detained and subsequently attacked, during which she witnessed her companions being assaulted and ultimately killed.
Evidence and Testimonies
The prosecution's case relied heavily on Myrna Diones' identification of the accused and her detailed account of the events surrounding the crimes. She identified the accused through photo line-ups and courtroom appearances. Additional corroborating evidence included the discovery of the bodies and the injuries consistent with Myrna's testimony, including strangulation marks and stab wounds on the victims. The defense presented alibis for each accused, claiming they were on duty or engaged in other activities during the time of the crimes.
Trial Court's Decision
On July 2, 1993, the trial court convicted the five accused of the crimes charged, imposing penalties of reclusion perpetua for the murder charges and an indeterminate sentence for the frustrated murder charge. The court credited the testimonies of Myrna Diones as credible despite the defense's objections relating to inconsistencies in her statements. The trial court expressed concern about the impact of media coverage, which sensationalized the case but concluded that the testimonies sufficed to convince the court of the accused's guilt.
Appeal and Arguments
The convicted individuals appealed the trial court's decision, raising multiple points related to the credibility of witnesses and the inadequacy of evidence. They argued that inconsistencies in testimonies warranted acquittal, particularly those concer
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Case Background
- The case involves multiple charges against six accused individuals, all members of the Philippine National Police (PNP), including Jose Flores y Salinas, Manuel Corpuz y Lacuata, Romeo Artienda y Galvez, Amado Merca y Lopez, Edwin Tubiera y Detabli, and Leonito Macapagal.
- The accused were charged with:
- Criminal Case No. 92-CR-1358: Murder with Unintentional Abortion for killing Vivian Gonzales Diones, who was five months pregnant.
- Criminal Case No. 92-CR-1365: Murder for the death of Laurita Diones Nitcha.
- Criminal Case No. 92-CR-1366: Murder for the death of Zenaida Diones Ragadi.
- Criminal Case No. 92-CR-1407: Frustrated Murder for the attempted murder of Myrna Diones y Nitcha.
- The alleged incidents took place between June 18 and June 19, 1992, along Naguilian Road, Banangan, Municipality of Sablan, Benguet.
Nature of the Crimes
- The crimes were characterized by:
- Use of conspiracy, confederation, and mutual aid among the police officers.
- Employment of superior strength, evident premeditation, and cruelty.
- The aggravating circumstance of nocturnity was present, utilized to facilitate the commission of the crimes.
Court Proceedings
- All accused pleaded not guilty during arraignment.
- The trial court conducted a joint trial for all cases, leading to a verdict on July 2, 1993.
- The court found the accused guilty of the aforementioned crimes with the following sentences:
- Criminal Case No. 92-CR-1358: Reclusion perpetua for the murder with unintentional abortion.
- Criminal Case No. 92-CR-1365 and No. 92-CR-1366: Reclusion perpetua for the murders.
- Criminal Case No. 92-CR-1407: Indeterminate sentence of 10 years