Case Summary (G.R. No. 72744-45)
Applicable Law
The case is decided under the provisions of the 1987 Philippine Constitution and relevant criminal laws regarding murder and frustrated murder.
Proceedings and Decisions
Following the trial court's decision imposing the death penalty on Jimmy Manambit, a notice of appeal was filed. Meanwhile, Mauricio Llames and Ramon Mamuri successfully petitioned for bail. Procedural issues arose concerning the representation of Jimmy Manambit, leading to the appointment of a counsel de oficio due to the failure of his new counsel to file a brief in a timely manner.
Allegations and Initial Charges
The accused faced two charges stemming from the same incident:
- The murder of Reynaldo Baldemora in Criminal Case No. SC-2209.
- The attempted murder of Hector Samonte in Criminal Case No. SC-2210.
Both charges were based on claims of conspiracy among the accused, with allegations involving the use of unlicensed firearms.
Evidence for the Prosecution
The prosecution presented testimony from Hector Samonte, who recounted the fateful events leading to the shooting. He described suspicious signals from Tony Manambit to the other accused before the attack. Samonte identified the armed men at the scene as the accused. Other witnesses provided corroboration of the sequence of events, including the recovery of firearms and spent shells suggesting a simulated ambush.
Evidence for the Defense
The defense employed alibi and denial strategies. The accused claimed they were elsewhere at the time of the incident. Testimonies were presented to establish their respective alibis, including Tony's account of being at a card game, Llames’ statement of being occupied at a truck repair shop, and others asserting they were not near the scene of the crime.
Trial Court's Findings
The trial court found sufficient evidence to convict Jimmy Manambit, Llames, and Mamuri. It determined that the prosecution’s witnesses, despite their alleged biases, presented a credible case that implicated the accused. Conversely, it acquitted Antonio Manambit, Rana, and Lacbay based on the lack of direct evidence against them.
Appeal and Preservation of Evidence
The appeal raised several crucial issues regarding the reliability of the witness testimonies, the alleged bias stemming from the familial feud, and the legal grounds for convicting the accused. The appellate court scrutinized the assumptions made by the trial court, particularly its findings about the presence of unidentified assailants, which contradicted the evidence of multiple attackers.
Court of Appeals Ruling
The appellate court found the prosecution’s evidence insufficient to satisfy the burden of proof necessary for a conviction. Key points outlined included:
- Motive: The intense historical animosity between the Manambits and Samontes potentially biased the testimonies provided by the latter.
- Credibility of Witnesses: The contradictions in the narratives of key witnesses, particularly regard
Case Syllabus (G.R. No. 72744-45)
Case Background
- The case involves multiple accused charged with murder and frustrated murder stemming from an incident on August 29, 1978, in Pagsanjan, Laguna.
- The trial court imposed the death penalty on Jimmy Manambit, prompting an appeal.
- The accused, including Jimmy Manambit, were arrested and subsequently filed notices of appeal after being found guilty.
Charges and Accusations
- Criminal Case No. SC-2209:
- Accused attacked and shot Reynaldo Baldemora while he was on a motorcycle, leading to his death.
- Criminal Case No. SC-2210:
- Accused shot Hector Samonte while he was driving a motorcycle, but he survived due to timely medical assistance.
- All accused pleaded not guilty during arraignment.
Evidence for the Prosecution
- Prosecution's Narrative:
- Hector Samonte and Reynaldo Baldemora were traveling to Magdalena when they passed by the house of Tony Manambit, who made hand signals to Ramon Mamuri.
- Upon their return, they were ambushed by four armed men, leading to gunfire.
- Eyewitness accounts noted the presence of the accused and their involvement in the shootings.
- Witness Testimonies:
- Hector identified the shooters, including Tony and Jimmy Manambit.
- Multiple police testimonies corrobor