Case Summary (G.R. No. 132696)
Charges and Proceedings
The accused faced two separate charges: Murder (Criminal Case No. 3082-A) and Aggravated Illegal Possession of Firearm and Ammunition (Criminal Case No. 3083-A). The prosecution alleged that, on the evening of August 28, 1987, Navarro shot Calizar with intent to kill, utilizing treachery and the cover of darkness.
Prosecution's Evidence
The prosecution relied heavily on the testimony of Bob Regaspi, who claimed to have witnessed the crime. Regaspi testified that he saw Navarro exit a jeep, pull Calizar from it, kick him, and then shoot him three times using a .45 caliber pistol under the illumination of surrounding vehicle lights. Regaspi admitted that he did not report the crime immediately out of fear for his life, leading to his relocation to Manila for three years.
Additional Testimonies
Other witnesses for the prosecution included Demetria Calizar, the victim's wife, who confirmed that Regaspi identified Navarro as the murderer. Medical testimony regarding the cause of death certified it as “severe hemorrhage due to multiple gunshot wounds.” Police officers corroborated the occurrence of the shooting and found evidence at the crime scene.
Defense's Case
The defense called several witnesses, including Mayor Leon Rivera, who testified about Navarro's character; however, he acknowledged the community's fear of Navarro's alleged criminal affiliations. Other defense witnesses sought to portray inconsistencies in Regaspi’s testimony, suggesting he may be implicated in the murder alongside the victim's widow, Demetria.
Trial Court's Verdict
The trial court convicted Navarro of Murder with the use of an unlicensed firearm, sentencing him to reclusion perpetua and ordering the payment of damages to the victim’s heirs. The court found the prosecution's evidence credible, despite attempts from the defense to undermine it through allegations of bias and conspiracy among witnesses.
Analysis of Appellant's Arguments
Navarro's appeal raised several points:
Inconsistency in Testimony: He claimed that Regaspi’s testimony was uncorroborated and led to a wrongful conviction. However, the appellate court noted that minor inconsistencies do not significantly detract from a witness's credibility.
Judicial Notice of Reputation: Navarro contested the trial court's consideration of extraneous facts regarding his notoriety. The appellate court clarified that the conviction was primarily based on Regaspi's direct eyewitness account.
Timing of Crime: Accused-appellant argued that committing the murder under bright conditions made his actions implausible. The court counte
Case Syllabus (G.R. No. 132696)
Case Overview
- Ramon Navarro (accused-appellant) was convicted of Murder with the Use of an Unlicensed Firearm and sentenced to reclusion perpetua by the Regional Trial Court, Branch 54, Alaminos, Pangasinan.
- The court ordered Navarro to indemnify the heirs of the victim, Romeo Calizar, in the amount of P100,000.00.
Charges Filed
- Two separate Informations were filed against Navarro:
- Murder (Criminal Case No. 3082-A): Alleged that on August 28, 1987, Navarro intentionally shot Romeo Calizar with treachery and evident premeditation.
- Aggravated Illegal Possession of Firearm and Ammunitions (Criminal Case No. 3083-A): Charged Navarro with possessing a handgun without a license, which was used in the murder.
Trial Proceedings
- Navarro was not allowed to post bail and pleaded not guilty to both charges during his arraignment.
- A joint trial was held for both cases, with the prosecution primarily relying on the testimony of Bob Regaspi, a key eyewitness.
Prosecution's Account
Bob Regaspi's Testimony:
- On the evening of the incident, Regaspi saw Navarro exit a jeep carrying a .45 caliber gun.
- He witnessed Navarro forcibly pull Calizar from the jeep, kick him, and shoot him three times.
- Regaspi identified Navarro despite the nighttime setting due to sufficient illumination from nearby vehicles.
- He did not report the crime immediately due to fear of Navarro's reputation as a killer.
Other Witnesses:
- Demetria Calizar: The victim's wife, who confirmed Regaspi's c