Case Summary (G.R. No. L-17958)
Applicable Law
The primary legal basis for the proceedings is the Revised Penal Code of the Philippines, specifically Article 248 concerning murder. The decision on this case is informed by the legal standards in effect, including the relevant articles concerning minors and the imposition of the death penalty.
Facts of the Case
On August 22, 1972, Munoz and Millora, both security personnel for the Mayor of San Carlos City, approached Ricardo Depacina while armed. Eyewitnesses testified that Munoz shot Depacina in the forehead while Millora stood by, brandishing a gun. Following the shooting, the defendants loaded Depacina's body into their police patrol jeep and transported it to Calasiao, where it was subsequently discovered.
Trial Court's Rulings
The trial court found Munoz guilty of murder and sentenced him to death, citing the aggravating circumstance of treachery. In contrast, Millora, because of his young age—only fourteen years—had his judgment suspended, being placed under the custody of Brigadier General Tomas P. Diaz.
Appellants' Arguments
Feliciano Munoz raised several errors regarding the trial court's findings. He contended:
- Error in Determining Guilt: He argued that the prosecution witnesses failed to convincingly identify him as the shooter.
- Admission of Confession: He claimed his confession was coerced and therefore should not have been considered.
- Insufficiency of Evidence: He asserted that the defense's evidence was not overcome by the prosecution's case.
Justo Millora contested the trial's failure to accept his alibi and the absence of conspiracy evidence linking him to Munoz’s alleged crime.
Evaluation of Evidence
Testimonies and Confession
The court evaluated witness testimonies. Munoz's challenge on the credibility of witnesses was rebutted effectively by the prosecution, maintaining that the minor discrepancies in their accounts did not detract from their overall reliability. Furthermore, Munoz's confession, although contested, was admissible under the prevailing presumption of voluntariness, as he failed to substantiate claims of coercion.
Alibi Defense
Munoz's alibi was undermined by witness testimonies establishing that the shooting occurred promptly after their arrival at the scene. The court emphasized that an alibi must be substantiated by evidence demonstrating physical impossibility to commit the crime, a standard not met by Munoz. Millora's alibi similarly lacked corroboration from named witnesses.
Aggravating and Mitigating Circumstances
The court upheld the conclusion of treachery, noting that the defendants utilized surprise in attacking an unarmed victim, thereby ensuring his inability to defend himself. The defense’s claim regarding the incidental use of a police vehicle was dismissed. The court concluded that the use of the police patrol jeep facilitated the crime and subsequent concealment of evidence, which constituted an aggravating circumstance.
Final Judgement
The Supreme Court amended the lower court's ruling, converting Munoz's sentence from death to reclusion perpetua, on the basis that treachery was the only established aggravating
...continue readingCase Syllabus (G.R. No. L-17958)
Case Overview
- This case involves the appeal by Feliciano Munoz and Justo Millora against their conviction for the crime of Murder.
- The decision arises from the Court of First Instance of Pangasinan, Third Judicial District, Branch XI, dated November 26, 1973.
- Feliciano Munoz was sentenced to death, while Justo Millora, a minor at the time of the crime, had his sentence suspended and was committed to the custody of a military officer.
Charges and Background
- Both defendants were charged with Murder under Article 248 of the Revised Penal Code for the killing of Ricardo Depacina on August 22, 1972.
- The information stated that the accused conspired to kill Depacina, armed with firearms and acting with evident premeditation and treachery.
- The crime occurred in San Carlos City, Pangasinan, where both accused were employed as security personnel for the city mayor.
Incident Details
- The incident transpired in the afternoon when the accused, driving a police patrol jeep, approached the victim.
- Witnesses testified that Munoz shot Depacina in the forehead while Millora stood ready with another firearm.
- After the shooting, the body of Depacina was loaded into the jeep, and they transported it away from the scene.
Trial Proceedings
- During the trial, both accused pleaded "Not Guilty."
- The prosecution presented several witnesses who directly testified about the crime, including law enforcement personnel and civilians.
- The defense countered with alibis and challenged the credibility of the prosecution's witnesses.
Appellants' Arguments
Feliciano Munoz's Assignments of Error:
- Disputed the tr