Title
People vs. Lapura y Cajan
Case
G.R. No. 94494
Decision Date
Mar 15, 1996
Special agent Petronilo Lim was ambushed and killed in Tondo, Manila, in 1988. Eyewitness identified Dionisio Lapura as the shooter; alibi defense rejected. Supreme Court upheld murder conviction, citing treachery and credible testimony.

Case Summary (G.R. No. 94494)

Charge and Conviction

The Regional Trial Court of Manila, Branch 12, convicted Dionisio Lapura y Cajan of murder, imposing the penalty of reclusion perpetua. The information, charging Lapura with murder, was filed on March 1, 1988, alleging that he, along with others still unknown, conspired to kill Lim by firing multiple shots at him using a .45 caliber pistol.

Evidence and Trial Proceedings

At trial, testimonies revealed that the victim was ambushed while driving on Honorio Lopez Blvd. Witness Edgardo Samson identified Lapura as one of the assailants who fired from the left side of Lim's car. The prosecution established the victim died from three gunshot wounds, with forensic evidence indicating they were inflicted at close range.

Defense Strategy

Lapura's defense centered around an alibi, claiming he was asleep at his sister’s house at the time of the shooting. This alibi was corroborated by his sister, but the trial court ultimately rejected it in favor of the prosecution's evidence, including the eyewitness account.

Legal Issues Raised

Lapura raised several legal arguments on appeal, claiming the trial court should have dismissed the case due to procedural flaws concerning the filing of the information without proper authority from the city prosecutor. However, the court upheld the presumption of regularity in official functions, dismissing this argument as unsubstantiated.

Motion for Acquittal and Procedural Concerns

The appeal also contended that the trial court should have considered alleged contradictions in Samson's testimonies as grounds for dismissal. However, the court found no material inconsistencies that would affect Samson’s credibility, especially given his identification of Lapura during a police line-up and later in court.

Right to Legal Counsel

Lapura also argued that his right to legal counsel was violated during the police line-up. However, the court noted that his attorney was present during the investigation, which contradicts Lapura's claim of being unassisted.

Conclusion on Appeal

The appellate court found the trial co

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