Case Summary (G.R. No. L-70308)
Summary of Events Leading to the Murder
After winning the election for a representative seat, Julio Nalundasan was murdered on September 20, 1935. His murder followed a provocative celebration by Nalundasan’s supporters, which deeply humiliated Mariano Marcos. An investigation ensued, initially leading to the prosecution of Nicasio Layaoen, who was acquitted. Following this acquittal, Mariano Marcos and three others were eventually charged with the murder based on an information that outlined a conspiracy to kill Nalundasan.
Accusation and Charges
The Charge against Mariano Marcos and his co-defendants alleged that they conspired to murder Julio Nalundasan. According to the information, they armed themselves and executed the crime with premeditation and malice. The evidence presented during the trial relied heavily on the testimony of Calixto Aguinaldo, who claimed to be an eyewitness to the conspiracy and murder.
Proceedings and Initial Verdict
During the trial, the defendants filed complaints against Aguinaldo for allegedly providing false testimony. However, these complaints were dismissed by the trial court. The resulting verdict found Quirino Lizardo and Ferdinand Marcos guilty of murder, while Mariano R. Marcos and Pio Marcos were acquitted. The court imposed significant prison sentences on the convicted defendants and also found them guilty of contempt for disrupting the trial process.
Legal Arguments on Appeal
The defendants appealed their convictions on several grounds, mainly focused on the credibility of Aguinaldo’s testimony, the alleged contradictions in the evidence, and the perceived disparities in treatment between the acquitted and convicted co-defendants. The appeal underscored the lack of direct evidence linking Ferdinand Marcos and Quirino Lizardo to the murder beyond Aguinaldo’s questionable account.
Review of Evidence and Credibility Issues
The appellate court scrutinized Aguinaldo’s testimony, revealing inconsistencies and a notable delay in his reporting of the events following Nalundasan's murder. It raised concerns over Aguinaldo’s potential motives in testifying against the defendants and his credibility as a co-conspirator. The court emphasized that the prosecution's reliance on Aguinaldo's testimony as primary evidence presented substantial doubt about the defendants' guilt and raised questions about the prosecution’s case being based on merely circumstantial evidence.
Conclusion of the Appellate Court
The court ultimately reversed the lower court’s decision, acquitting Ferdinand Marcos and Quirino Lizardo of murder, as the prosecution failed to establish their guilt beyond a reasonable doubt. The acquittal emphasized that motive alone does not equate to gui
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Case Overview
- The case involves an electoral rivalry between Mariano Marcos and Julio Nalundasan for the position of representative in Ilocos Norte.
- Julio Nalundasan was elected in 1934 but was later killed on September 20, 1935, after another electoral victory over Mariano Marcos.
- Following Nalundasan's murder, a series of investigations were conducted, leading to the prosecution of Mariano Marcos, Pio Marcos, Ferdinand Marcos, and Quirino Lizardo.
Background of the Case
- The rivalry between Nalundasan and Mariano Marcos intensified after Nalundasan's election victory in 1934 and continued into the 1935 elections.
- Nalundasan’s supporters held a celebratory parade that was seen as humiliating for Mariano Marcos, which may have contributed to the motive for the murder.
- After the initial suspect, Nicasio Layaoen, was acquitted of the murder charge, further investigations resulted in the prosecution of the Marcoses and Lizardo.
Charges and Prosecution
- The defendants were charged with murder, described in the information as a planned conspiracy to kill Nalundasan using firearms.
- The prosecution's case relied heavily on the testimony of Calixto Aguinaldo, who alleged to have been a witness and participant in the conspiracy.
- Aguinaldo's testimony suggested that Ferdinand Marcos was chosen as the trig