Case Summary (G.R. No. 191723)
Charges and Initial Proceedings
The public prosecutor filed multiple charges against the accused. Criminal Case No. 2001-5445 charged them with frustrated murder concerning Roger Aringo. In separate Informations, Criminal Case Nos. 2001-5446, 2001-5447, and 2001-5448 charged them with murder for the deaths of Edgardo, Benjamin, and Carlito Aringo, respectively. The accused pleaded not guilty, and the cases were tried separately.
Prosecution's Presentation of Evidence
The prosecution presented eyewitness testimony from Roger Aringo, the surviving victim, along with testimonies from other witnesses, including the attending physician Dr. Antonio Lopez and various relatives of the victims. The prosecution established that the accused approached the fishpen under cover of night, armed with firearms, and opened fire on the victims, resulting in fatal injuries to Edgardo, Benjamin, and Carlito, while Roger sustained life-threatening injuries.
Defense Argument
The defense countered the allegations with an alibi, asserting that the accused were elsewhere during the commission of the crimes. Witnesses were presented to corroborate their claims, testifying that they were involved in duties unrelated to the incident. However, these testimonies lacked substantive evidence to contradict the prosecution's assertions.
Trial Court Decisions
The Regional Trial Court (RTC) Branch 53 convicted the accused of frustrated murder against Roger Aringo and sentenced them accordingly, while RTC Branch 52 convicted them of murder for the deaths of the three victims. Both courts found the prosecution's evidence credible, emphasizing the spontaneous and credible nature of Roger's testimony.
Appeal and Court of Appeals Decision
The accused-appellants appealed their convictions to the Court of Appeals, arguing insufficient evidence and the effectiveness of their alibi. The Court of Appeals affirmed the decisions of the RTCs, holding that the identification of the accused by Roger as the perpetrators was credible and unswervingly backed by the testimonies of expert witnesses.
Supreme Court's Review
Upon review, the Supreme Court noted that the trial courts' assessments of witness credibility had to be given due regard, as they directly observed the testimony. The prosecution had sufficiently established the identities of the accused through Roger's consistent and clear eyewitness account. The Supreme Court upheld the findings of conspiracy to commit murder, establishing each accused's culpability.
Affirmation of Convictions and Sentences
The Supreme Court affirmed the appellate court's decision while modifying certain aspects of the penalties. It upheld the sentences of reclusion perpetua for the murder counts and adjusted the penalties for the charge of frustrated murder. Additionally, the Court modified the civil indemnities and granted exemplary damages to the victims' heirs based on the seriousness of the crime.
Legal Standards Applied
To sustain a conviction for murder under Article 248 of the Revised Penal Code, the prosecution had to establish:
- The victim
Case Syllabus (G.R. No. 191723)
Case Overview
- This case is an ordinary appeal that seeks to reverse the consolidated Decision dated December 22, 2009, of the Court of Appeals.
- The appeal pertains to multiple criminal cases originating from the same set of facts, specifically involving charges of frustrated murder and three counts of murder against the accused-appellants.
- The case was adjudicated in the Regional Trial Courts (RTC) of Sorsogon City, with separate decisions rendered for each charge.
Background of the Case
- Filing of Charges: The public prosecutor filed charges on July 25, 2001, against Renato, Rolando, Armando, Gilberto, Merwin, Freddie, Salvador, all surnamed Las Piaas, and Jimmy Delizo.
- Nature of Charges: The charges included one count of frustrated murder (Criminal Case No. 2001-5445) and three counts of murder (Criminal Case Nos. 2001-5446, 2001-5447, and 2001-5448).
- Location and Context: The incidents occurred at a fishpen in Castilla, Sorsogon, during the early hours of May 2, 2001.
Facts of the Case
- Events Leading to the Incident:
- On the night of May 1, 2001, Roger Aringo and his brothers, Edgardo and Benjamin, along with their cousin Carlito Lasala, were at Edgardo's fishpen.
- They were attacked by the accused-appellants, who arrived in a boat and commenced shooting at them without warning.
- Victims and Injuries:
- Roger sustained significant injuries from gunfire, while Edgardo, Benjamin, and Carlito were killed during the attack.
- Roger testified that he witnessed the shooting of his companions and identified the assailants.
Trial Proceedings
- Prosecution's Evidence:
- The prosecution presented eyewitness testimony from Roger, medical evidence from Dr. Antonio Lopez, and testimonies from various family members of the victims.
- The evidence esta