Case Summary (G.R. No. L-33638)
Procedural History
Initially tried in the Court of First Instance of Bohol, the case was later transferred to a Circuit Criminal Court and assigned Criminal Case No. CCC-XIV 63-Bohol. On April 29, 1971, the trial court found Libardo guilty beyond reasonable doubt of double murder and sentenced him to death, considering the aggravating circumstances of his public position as a policeman alongside mitigating circumstances including his voluntary surrender.
Appellate Claims
Libardo appealed the trial court's decision, asserting that the court erred in believing the prosecution witnesses' testimonies over those of his defense witnesses, which he claimed were more credible and coherent. He also argued that the trial court failed to recognize the justifying circumstance of self-defense.
Factual Background of the Incident
According to the prosecution, the conflict was rooted in Libardo's desire to take control of the Inabanga Labor Union, initially led by Torres. The prosecution outlined a series of confrontational incidents leading up to the murders. On the day of the shooting, witnesses reported that Libardo shot both victims with a Thompson submachine gun and indicated a continued assault even after they fell.
Evidence and Witness Testimonies
Witnesses, including Flaviana Cenita, Carina Cenita, and Mamerto Petalcorin, provided consistent accounts of Libardo's actions at the scene, detailing his approach to the victims and subsequent shooting of the deceased while they were incapacitated. Moreover, forensic evidence corroborated the findings of multiple gunshot wounds consistent with a submachine gun attack.
Self-Defense Argument
The defense claimed that Libardo acted in self-defense, alleging that Melicor attacked him, leading to a struggle for the firearm. Libardo asserted that he had to shoot in retaliation after Torres attempted to draw his weapon against him. However, the prosecution contested this narrative, highlighting a lack of credible witnesses and evidence to substantiate the self-defense claim.
Evaluation of Self-Defense Claims
To establish self-defense under the Revised Penal Code, three elements must be proven: (1) unlawful aggression, (2) reasonable necessity of the means employed, and (3) lack of provocation by the defender. The court found Libardo's assertions unconvincing, as the testimonies of prosecution witnesses painted a picture of a deliberate and unprovoked attack.
Credibility Determination
The trial court's assessment of witness credibility favored the prosecution. The judge noted the manner of testimonies, consistency of accounts, and the absence of evidence undermining their integrity. In contrast, Libardo’s defense witnesses exhibited biases that weakened their credibility.
Judicial Findings on Murder
The court confirmed that the killing unfolded with evident premeditation and treachery, as Libardo's sudden attack did not permit the victims to defend themselves. The court acknowledged Libardo's violation of duty given his role as a policeman, thus affirming the aggravating circumstance of abuse of public position without determining evidence of vindictiveness.
Final Ruling
Ultimately, while th
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Case Overview
- The case involves Alfredo Libardo, a municipal patrolman in Inabanga, Bohol, accused of double murder in the shooting deaths of Exequio Torres and Ismael Melicor on January 25, 1969.
- The trial court found Libardo guilty beyond reasonable doubt, sentencing him to death with damages awarded to the victims' heirs.
- Libardo appealed the trial court's decision, claiming errors in the appreciation of evidence and the failure to consider his self-defense argument.
Background of the Case
- The incident occurred against a backdrop of tension between Libardo, a suspended police officer, and the victims, who were involved with the Inabanga Labor Union (ILU).
- Libardo had previously expressed intent to take over the leadership of the ILU, creating animosity with Torres, the union's president.
- Witness accounts detailed Libardo's aggressive behavior leading up to the shooting, including threats made against Torres.
Events Leading to the Shooting
- On the day of the incident, witnesses observed Libardo armed with a Thompson submachine gun in the public market.
- Witnesses, including Flaviana Cenita and Mamerto Petalcorin, testified to hearing gunfire and seeing Libardo shoot Torres and Melicor, who were unarmed.
- After shooting, Libardo reportedly approached the bodies, fired additional shots into Torres's corpse, and subsequently fled the scene.
Trial Court Proceedings
- The trial court evaluate