Case Summary (G.R. No. L-32624)
Summary of Charges and Proceedings
The appellants, Doblen, Rojas, and the Nierra spouses, were convicted of murder and sentenced to death by Judge Pedro Samson C. Animas of the Court of First Instance of South Cotabato for their roles in the assassination of Juliana Nierra. Gaspar Misa, who had pleaded guilty, received the same sentence but was subject to automatic review. The court ordered the accused to pay a solidary indemnity of 12,000 pesos to the heirs of the victim.
Motivation Behind the Murder
The prosecution's evidence indicated that Paciano Nierra was motivated by a desire to eliminate Juliana, a business competitor in the launch transportation and soft drink sales market. The rivalry was exacerbated by strained family relations, with Juliana being the sister-in-law of Paciano. Aniceto Nierra, Juliana's husband, sought to reduce competition by selling one of Juliana’s launches to Paciano, yet this did not mend their relationship.
Planning and Execution of the Crime
On July 4, 1969, Misa was recruited to carry out the assassination for a payment of 3,000 pesos, facilitated by Doblen, a cousin-in-law of Paciano. Misa conspired with Rojas, who acted as a lookout during the crime, as well as with Gaudencia Nierra, who also agreed to the plot. The murder was planned to take place on the night of July 8, 1969.
The Commission of the Murder
The murder occurred when Misa ambushed Juliana while she was near her house, resulting in her death by a gunshot wound. Paciano and Gaudencia Nierra were reportedly close enough to witness the murder. Misa's escape from the scene was deliberate, and he later attempted to collect a portion of the payment for the crime from Paciano after it was committed.
Confession and Testimony
Misa's confession to the police was crucial, as he explicitly implicated the Nierra spouses, Doblen, and Rojas. His confessions were supported by a reenactment of the crime and additional testimonies that corroborated his narrative. The prosecution also highlighted that Misa had a history of criminal behavior, which fortified his credibility as a witness regarding the motivations and executions surrounding the murder.
Defense Strategies and Contentions
The defense for the Nierra spouses claimed they were not involved in any conspiracy and provided alibis for the night of the murder. They argued Misa lacked credibility due to inconsistencies in his statements and his prior criminal record. However, these arguments were deemed insufficient, as the evidence presented ultimately pointed toward their collusion in the murder.
Court's Findings on Conspiracy and Guilt
The trial court found compelling evidence demonstrating that the Nierra spouses had conspired with Misa and Doblen to carry out the assassination of Juliana Nierra. Their financial incentive and the act of coordinating with Misa for the execution were sufficiently substantiated. The court dismissed the idea that alibi defenses could absolve the Nierra s
...continue readingCase Syllabus (G.R. No. L-32624)
Case Citation
- Jurisprudence: 185 Phil. 1 EN BANC
- G.R. No. L-32624
- Date: February 12, 1980
Parties Involved
- Plaintiff-Appellee: The People of the Philippines
- Accused-Appellants:
- Paciano Nierra (alias Pacing)
- Gaudencia Nierra
- Felicisimo Doblen (alias Simoy)
- Vicente Rojas
- Gaspar Misa (Accused whose death sentence is under automatic review)
Trial Court Proceedings
- Trial Court: Court of First Instance of South Cotabato, General Santos City Branch II
- Judge: Pedro Samson C. Animas
- Original Decision Date: March 4, 1970
- Sentences:
- Conviction for murder for all accused.
- Death penalty for each accused.
- Solidary indemnity of twelve thousand pesos to the heirs of the victim, Juliana Nierra.
Background of the Case
- Juliana Gadugdug-Nierra, 52, and Paciano Nierra, 39, were business competitors in the launch transportation and soft drink industry in Barrio Tinago, General Santos City.
- Juliana owned two motor launches and sold Coca-Cola, while Paciano owned two launches and sold Pepsi-Cola.
- Familial relations complicated the rivalry, as Aniceto Nierra, Juliana's husband, is Paciano's elder brother.
Motive for the Crime
- Paciano Nierra allegedly sought to eliminate Juliana to monopolize their business interests in the locality.
- After an attempt to reduce competition by selling one of Juliana’s launches, Paciano conceived a plan to kill her.
Conspiracy and Execution of the Crime
- Paciano Nierra hired Gaspar Misa, a convicted murderer, to kill Juliana for a sum of three thousand pesos.
- Felicisimo Doblen facilitated this plot by delivering a .38 caliber pistol to Misa.
- Vicente Rojas