Case Summary (G.R. No. 193945)
Overview of Events Leading to the Charges
On the morning of April 11, 1985, the accused gathered at an eatery to discuss plans for the execution of alleged communist sympathizers. The conspiring individuals noted names on a cigarette wrapper, indicating intended targets. Throughout the day, these discussions and subsequent violent actions indicated a clear conspiracy to commit murder and other violent acts against their targets.
Trial Court Findings and Convictions
The Regional Trial Court ultimately convicted the Manero brothers, along with their co-accused, of murder, attempted murder, and arson. Each accused was sentenced to penalties of reclusion perpetua for murder, varying imprisonment terms for attempted murder, and lesser terms for arson. The trial court also ordered substantial civil indemnities and attorney’s fees to be paid to the Pontifical Institute of Foreign Missions, which the priest belonged to.
Defense of Alibi and Its Rejection
The appellants claimed an alibi, stating they were engaged in other activities far from the crime scene. However, the court found their alibi unconvincing due to the proximity between their claimed locations and the scene of the crime. The evidence presented demonstrated their presence at the site throughout the day of the murder, undermining their defense.
Conspiracy and Collective Responsibility
The court established that there was clear evidence of conspiracy among the accused, demonstrating a shared intent to carry out the crimes. The evidence included the direct participation of the appellants in the events leading to the murder of Fr. Favali, showcasing that they were not just incidental witnesses but rather active participants in the conspiracy.
Impact of the Murder on the Victim's Family
Although moral damages were requested, the appellate court determined that the Pontifical Institute was not entitled to such damages, as it is a juridical entity and cannot experience emotional suffering. However, exemplary damages were granted due to the brutal nature of the crime, and the civil indemnity for Fr.
...continue readingCase Syllabus (G.R. No. 193945)
Case Overview
- This case revolves around the gruesome murder of Fr. Tulio Favali, an Italian Catholic priest, on April 11, 1985, in Tulunan, Cotabato, Philippines.
- The murder was committed in broad daylight by a group of individuals, including Norberto Manero, Jr. and his co-accused, who executed the crime amidst laughter and revelry.
- The trial court found the accused guilty of murder, attempted murder, and arson, imposing severe penalties, including reclusion perpetua and civil indemnities.
Facts of the Case
- On the morning of April 11, 1985, the accused met at an eatery owned by Reynaldo Diocades to plot the murder of suspected communist sympathizers, including Fr. Peter Geremias.
- During the meeting, the conspirators discussed a list of targets, including Fr. Tulio Favali, whom they ultimately killed.
- The group, armed with various firearms, executed their plan by harassing and attempting to murder several individuals before killing Fr. Favali around 5:00 PM that day.
Details of the Murder
- The accused executed a well-planned attack, first targeting Rufino Robles (Bantil), a lay leader, and then turning their attention to Fr. Favali.
- Upon arriving, Fr. Favali discovered his motorcycle being set on fire by the Maneros, leading to a confrontation.
- Edilberto Manero shot Fr. Favali in the head after taunting him, followed by additional shots that disfigured the priest's body, causing onlookers horror.
- The murder was marked by mo