Case Summary (G.R. No. 191320)
Background of the Case
The case originated from the murder of Barangay Captain Abe Felonia, who was shot to death in a market. Accused Gerry Sabangan was identified as the shooter, while Noli Bornasal was initially charged but later acquitted due to reasonable doubt. The prosecution's key evidence included eyewitness testimony from several individuals who observed the shooting.
Proceedings Before the Regional Trial Court (RTC)
During the trial, the prosecution presented multiple witnesses, including eyewitnesses Eden Allado and Flora Navales, who directly identified Sabangan as the shooter. Testimonies detailed the circumstances surrounding the crime, including the involvement of both the accused in fleeing the crime scene. The prosecution also submitted relevant documentary evidence to support claims of damages suffered by Felonia's heirs.
Defense Strategy
Sabangan and Bornasal entered a plea of not guilty, asserting alibis that placed them in different locations at the time of the murder. The defense relied heavily on witness accounts from relatives who claimed both accused were preparing for a wedding in a distant barangay. However, the credibility of these defensive witnesses was called into question due to insufficient corroborating evidence.
RTC Decision
The RTC convicted both Sabangan and Bornasal of murder, predicated on the established presence of treachery during the commission of the crime. The court sentenced Sabangan and Bornasal to reclusion perpetua and ordered them to pay various forms of damages to Felonia's heirs.
Appeal to the Court of Appeals
On appeal, Sabangan maintained that the prosecution failed to adequately establish his guilt beyond a reasonable doubt and reiterated his alibi. The Court of Appeals upheld Sabangan’s conviction but acquitted Bornasal due to insufficient evidence establishing his direct involvement in the murder.
Court of Appeals Ruling
The appellate court affirmed Sabangan's conviction for murder, stating that both the eyewitness accounts and circumstantial evidence sufficiently established his guilt. However, it modified the damages awarded, recognizing the actual expenses proven during trials while adjusting other damage awards.
Supreme Court Review
The Supreme Court ultimately upheld the conviction, reinforcing the principle that positive identification by credible witnesses outweighs unsupported alibi de
...continue readingCase Syllabus (G.R. No. 191320)
Case Overview
- This case involves an appeal from the Decision dated November 20, 2009, by the Court of Appeals, which modified the Decision dated November 25, 2004, made by the Regional Trial Court (RTC) in Criminal Case No. 46,888-01.
- The RTC had convicted accused-appellant Gerry Sabangan for the murder of Barangay Captain Abe Felonia, while acquitting the co-accused Noli Bornasal.
- The appeal was filed by Sabangan, challenging the RTC's judgment and the nature of the evidence against him.
Background of the Case
- The Information was filed with the RTC on February 21, 2000, identifying Sabangan as the perpetrator; Bornasal was initially called "John Doe" due to his absence.
- Sabangan pleaded not guilty during his arraignment, while Bornasal was later included in the Information and also pleaded not guilty after his arrest on June 13, 2002.
- The prosecution's case was built on witness testimonies and circumstantial evidence.
Prosecution Evidence
- Witnesses included Eden Allado and Flora Navales, who witnessed Sabangan shoot Felonia; Marlon Cordero, who saw both accused fleeing the scene; and the Chief of Police, Roberto Badian, who investigated the incident.
- Various documentary evidence was presented including sworn statements, police affidavits, and receipts for funeral expenses.
- Key testimony from Helen Felonia Galladora, the victim's daughter, detailed the emotional and financial impact of her father's death on the family.
Key Testimonies
- Eden Allado: Described being present in the store when she witnessed Sabangan shoot Fel