Case Summary (G.R. No. L-8024)
Summary of Indictments
Bernard Mapalo was charged with murder for the death of Manuel Piamonte, allegedly committed with intent to kill, using lead pipes and bladed weapons in a concerted attack on February 13, 1994. After the Regional Trial Court (RTC) found him guilty and sentenced him to reclusion perpetua, he appealed the decision, which was subsequently modified by the Court of Appeals, finding him guilty of frustrated murder instead.
Prosecution's Case
The prosecution's case relied on the testimony of sole eyewitness Calixto Garcia, who claimed to have seen the appellant strike Piamonte with a lead pipe during an altercation at a pre-Valentine dance. Garcia testified that he could clearly see the incident from a distance of about five meters. Although Garcia confirmed he witnessed the initial attack, he did not see who inflicted the fatal stab wounds on Piamonte. His testimony included details about the size and nature of the weapon used.
Defense's Position
The defense, led by Bernard Mapalo, presented an alibi claiming he was at home with his wife during the incident. Caridad Mapalo corroborated her husband's account, stating they entertained guests early in the evening and did not leave their residence until later. They both asserted they were unaware of the fighting at the dance hall until they heard commotion around 3:00 a.m.
Ruling of the RTC
The RTC found Bernard Mapalo guilty of murder, dismissing his alibi based on the proximity of his house to the dance hall. The Court emphasized the strength of the eyewitness account, concluding that the defense's claims did not provide a compelling reason to doubt the presence of the accused at the crime scene. The Court further noted the established conspiracy due to the involvement of multiple accused and the use of superior strength against the victim.
Ruling of the Court of Appeals
The Court of Appeals upheld the conviction on appeal, yet modified the charge to frustrated murder due to insufficient evidence proving conspiracy among the co-accused. The appellate court highlighted the failure of the eyewitness to specify who inflicted the stab wounds and pointed out that the incident arose from a spontaneous fight rather than a premeditated attack. Therefore, it ruled that without proof of concerted action, the appellant could only be held accountable for his individual violence.
Issues Raised by the Appellant
The appellant raised two primary issues:
- He was not positively identified in court by the prosecution witness, arguing this failure undermined the prosecution's case.
- He contended that if convicted, the charge should be for frustrated homicide instead of frustrated murder.
Court's Analysis
Addressing the first issue, the court concluded that positive identification in court was not indispensable as the witness had known the appellant prior to the incident. The testimony of Garcia was deemed reliable despite the lack of a formal in-court identification, as he was familiar with both the appellant and the victim. The appellate court found no compelling evidence of misidentification to override the witness's testimony.
Regarding the second issue, the court agreed
...continue readingCase Syllabus (G.R. No. L-8024)
Case Background
- The case involves Bernard Mapalo, who was initially found guilty of Murder by the Regional Trial Court (RTC), Branch 32 of Agoo, La Union, on October 27, 2004, and sentenced to reclusion perpetua.
- The ruling was appealed, and the Court of Appeals modified the decision, convicting Mapalo of Frustrated Murder instead.
- The incident occurred on February 13, 1994, in Aringay, La Union.
Indictments and Charges
- Bernard Mapalo was charged with Murder alongside co-accused Peter Doe, John Doe, and Rolando Mapalo alias "Lando."
- The accusation stated that the group conspired to kill Manuel Piamonte using lead pipes and bladed weapons, resulting in Piamonte's death from multiple stab wounds.
- An arrest warrant was issued, and Mapalo was apprehended while others remained at large.
Prosecution's Case
- The primary eyewitness for the prosecution, Calixto Garcia, testified he saw Mapalo club Piamonte with a lead pipe during a dance.
- Garcia observed the fight from approximately five meters away and claimed the blow was delivered to the right side of Piamonte's head.
- Garcia did not witness the stabbing directly but later saw Piamonte's body with multiple stab wounds, indicating the victim's death resulted from these injuries.
Defense's Case
- Bernard Mapalo presented an alibi, asserting he was at home entertaining guests on the evening of February 12, 1994, and only learned of the stabbing later.
- His wife, Caridad Mapalo, corroborated his alibi, claiming she did not see him leave their residence during the incident.
RTC Ruling
- The RTC ruled against Mapalo, emphasizing that the positive identification by Garcia outweighed