Case Summary (G.R. No. 215280)
Case Background and Procedural History
On March 1, 1994, an information for double murder was filed against the accused by Senior State Prosecutor Hernani T. Barrios. The trial commenced in the Regional Trial Court, Calamba, Laguna, with arraignments occurring on April 10, 1995, where all accused pleaded not guilty. On December 27, 1996, the Regional Trial Court convicted the four individuals of double murder, sentencing them to reclusion perpetua and ordering payment of damages to the victims' heirs. Appeals were subsequently filed by Sanchez and Averion.
Events Leading to the Crime
On April 13, 1991, the day of the incident, witness Vivencio Malabanan, a policeman and part of Sanchez’s security team, was informed by Peradillas about the possibility of a birthday party attended by Nelson PeAalosa, a political opponent. This led to an alleged conspiracy culminated in a planned ambush against the PeAalosas.
Execution of the Crime
Around 7:45 PM, the accused followed Nelson PeAalosa's vehicle, purportedly armed with automatic weapons. According to witness testimonies, including that of Malabanan, the accused fired multiple rounds at PeAalosa's jeep, resulting in both Nelson and his son Rickson sustaining fatal injuries.
Investigation and Autopsy
Following the shooting, law enforcement authorities arrived at the crime scene and retrieved the victims’ bodies. An autopsy conducted by Dr. Ruben B. Escueta confirmed death due to gunshot wounds. Ballistic tests linked empty shell casings at the scene to weapons associated with the accused.
Defense Strategy and Testimonies
The accused presented a defense of alibi, denying involvement in the crime and positing that they were being scapegoated for refusing to testify against Mayor Sanchez in a separate case. A cross-examination revealed inconsistencies between testimonies of the defense and witness accounts regarding the actions of Malabanan during the shooting.
Trial Court's Ruling
The trial court found that the prosecution had established the guilt of the accused beyond a reasonable doubt, highlighting the planning, execution, and conspiracy surrounding the murders. The court emphasized the presence of treachery and evident premeditation in its ruling and sentenced the accused accordingly.
Appeal Arguments
On appeal, Sanchez and Averion argued that the trial court failed to properly assess the inconsistencies between testimonies, particularly those of Malabanan and the autopsy findings. They contested the credibility of the witness based on these disparities and sought to undermine the prosecution's case.
Supreme Court Decision
The Supreme Court upheld the trial court's conviction but clarified that the complex crime of double murder was not applicable as the shootings constituted multiple acts due to the use of automatic weapons. The court emphasized that each shot fired represented a separate and distinct act of m
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Case Overview
- The case involves an appeal from the Regional Trial Court, Branch 160, Pasig City, which found the accused—Antonio L. Sanchez, Luis Corcolon, Landrito "Ding" Peradillas, and Artemio Averion—guilty beyond reasonable doubt of double murder.
- The victims, Nelson PeAalosa and Rickson PeAalosa, were murdered on April 13, 1991, in Barangay Curba, Calauan, Laguna.
- The trial court sentenced each accused to reclusion perpetua along with various damages to be paid to the victims' heirs.
Background of the Case
- The information for double murder was filed on March 1, 1994, by Senior State Prosecutor Hernani T. Barrios.
- The prosecution argued that the accused conspired to kill the PeAalosas using automatic weapons, premeditatedly and treacherously.
- The case was assigned to Branch 34 of the Regional Trial Court and later transferred to Branch 70 in Pasig City due to a request for a change of venue.
Events Leading to the Murder
- On the morning of April 13, 1991, state witness Vivencio Malabanan, who was part of the security detail for Mayor Sanchez, received information from Peradillas about a birthday party where Nelson PeAalosa would be present.
- The accused conspired to kill Nelson PeAalosa, a political rival of Mayor Sanchez.
- Preparations included acquiring two-way radios and a vehicle for the operation scheduled to take place that evening.
The Shooting Incident
- The accused executed their plan around 7:00 PM, pursuing the PeA