Case Summary (G.R. No. L-45088)
Charges and Initial Court Findings
Eustaquio Manalo was charged with the murder of Victor Saavedra, alleged to have occurred on September 15, 1973. The prosecution claimed that Manalo, armed with a shotgun, committed the act with treachery, evident premeditation, and intent to kill. Following the trial, the court found Manalo guilty and sentenced him to reclusion perpetua, imposed accessory penalties, and ordered him to indemnify the heirs of the victim an amount of P12,000. Manalo appealed the verdict.
Factual Background
The prosecution's narrative recounts that on the day of the shooting, Victor Saavedra was traveling with his family from Buug Mundo to Sibulao due to rising tensions in their area. At around 4:00 PM, Victor was shot while riding a carabao, with the family members witnessing the incident from a distance. Following the shots, Victor fell, and they observed Manalo approach the victim and take his belongings before fleeing the scene.
Medical Examination and Evidence
A medico-legal examination conducted by Dr. Rogelio Silapan confirmed multiple gunshot wounds on Victor, establishing the cause of death as shock and hemothorax due to gunshot wounds. Witnesses corroborated the timeline and details surrounding the shooting, with the widow Julia Saavedra eventually reporting the incident to authorities the following day.
Defense and Testimonies
Manalo did not testify in his defense; instead, Jose Ventura, a local barangay captain, claimed that Manalo was with him during the shooting and thus could not have committed the crime. Despite his alibi, the trial court found the testimonies of the prosecution witnesses—particularly that of Julia and her son—more credible. They identified Manalo as the assailant, and his alibi was not supported with evidence proving his whereabouts at the precise time of the incident.
Appeal and Judicial Considerations
In his appeal, Manalo's counsel criticized the trial court’s reliance on eyewitness accounts, asserting inconsistencies in their testimonies. However, the Supreme Court maintained that minor inconsistencies do not undermine the overall credibility when witnesses have definitively identified the accu
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Case Overview
- The case involves the charge of murder against Eustaquio Manalo y Rebollos, stemming from an incident on September 15, 1973, in Zamboanga City.
- The accusation specifies that the defendant, armed with a shotgun, fatally shot Victor Saavedra with treachery and evident premeditation.
- The trial court found Manalo guilty and sentenced him to reclusion perpetua, ordered him to indemnify the heirs of the deceased, and imposed accessory penalties.
Factual Background
- On the day of the incident, Victor Saavedra and his family were evacuating due to escalating violence in their community.
- Victor was riding a carabao pulling a sled laden with their belongings, followed by his son Bernardito on a cow, and his wife Julia with their younger child.
- Julia and Bernardito heard gunshots and witnessed Victor falling from the carabao, after which they hid among the bushes.
- They observed Eustaquio Manalo approaching Victor’s body with a shotgun, subsequently taking Victor's revolver and homemade shotgun before leaving the scene.
Medical Examination
- The following day, Victor Saavedra's body underwent a medico-legal examination by Dr. Rogelio Silapan.
- The examination revealed multiple gunshot wounds, with the cause of death identified as shock and hemothorax due to these wounds.
- The widow incurred significant expenses for the embalming and fun