Case Summary (G.R. No. 71142)
Factual Background
On the morning of October 2, 1982, Jaime Cordelin was shot and killed, with eyewitnesses confirming that Maralit and Pasia were among the assailants. The eyewitnesses described the attackers as firing from an elevated position as the victim and his two sons approached. A subsequent investigation uncovered multiple bullet shells, and a medical examination corroborated the violent nature of the attack, ruling the cause of death as multiple gunshot wounds.
Motive for the Crime
The motive for the murder stemmed from a land dispute between Jaime Cordelin and the International Realty Corporation, where the accused were employed. Tensions escalated after attempts by the Corporation's employees, including Pedro Pacheca (the deceased overseer), to forcibly remove Cordelin from the property he was farming. Evidence indicated past threats against the victim and acts of vandalism, including the burning of his huts, which aligned with the motives attributed to the accused.
Defense and Trial Verdict
Maralit and Pasia denied involvement in the killing, asserting they were working at the Corporation's farm at the time. Their alibi was supported by testimonies from their employer and colleagues. However, the lower court found the prosecution's witnesses credible and established a conspiracy among the accused, affirming Maralit’s participation in the crime. Ultimately, Romy Pasia was acquitted due to reasonable doubt, while Maralit was convicted of murder, receiving a sentence of reclusion perpetua and ordered to pay damages.
Appeal and Arguments
In his appeal, Maralit argued that the trial court erred by not recognizing that the conspiracy was limited to Pasia and Pacheca, contending that his presence was passive and did not warrant his conviction. He further claimed the defense had not sufficiently linked him to the murder due to the absence of a firearm in his possession.
Judicial Analysis of Conspiracy
The court found that the eyewitness accounts were consistent and reliable, confirming Maralit’s involvement alongside the other assailants. The presence of Maralit in close proximity to the crime scene and his actions supported the evidence of conspiracy. The court explained that conspiracy does not require direct evidence of participation in the actual killing but can be determined through the collective actions towards a common criminal goal.
Ruling on Alibi and Conspiracy
The appellate court clarified that the distance between the crime scene and Maralit's claimed location (only about four kilometers) was not enough to support an alibi since he could have feasibly reached the site of the murder within the timeframe. Furthermore, the court upheld established jurisprudence stating that an alibi must demonstrate impossibility of presence at the crime scene, which was not satisfactorily proven in Maralit’s case.
Qualifying Ci
...continue readingCase Syllabus (G.R. No. 71142)
Case Background
- The case revolves around the murder of Jaime Cordelin, a 63-year-old resident of Carmona, Cavite, which took place on October 16, 1982.
- A criminal complaint was filed against four individuals: Romy Pasia, Maning Mendoza, Pedro Pacheca, and Lope Maralit.
- Romy Pasia surrendered to authorities on November 15, 1982, while Mendoza was at-large, and Pacheca died in custody on November 9, 1982.
- Lope Maralit was apprehended later and both Maralit and Pasia faced charges of murder.
- During the trial, Pasia was acquitted on grounds of reasonable doubt, while Maralit was convicted of murder qualified by treachery and sentenced to reclusion perpetua.
Facts of the Case
- The victim had a land dispute with the International Realty Corporation, where the accused were employed.
- Eyewitnesses, Bienvenido and Danilo Cordelin (sons of the victim), testified that on October 2, 1982, they saw Maralit and Pasia, along with Pacheca and Mendoza, shoot at the victim while he was on his way to the farm.
- Evidence of the crime included empty shells from firearms found at the scene and the autopsy report detailing multiple gunshot wounds.
Prosecution's Case
- The prosecution established a motive related to the victim’s refusal to sell his land to the Corporation.
- Witnesses reported previous threats against the victim by the