Case Summary (G.R. No. L-21492)
Background and Incident
The fatal incident arose from a land dispute over a property in Goliptop, Dumingag, between the deceased, Maximo Candia, and the accused, Eleno and Enriquito Tapitan. The deceased and eyewitness Cleto Baranda were on the disputed land early in the morning, preparing to build a house after claiming rights to the land. Meanwhile, the Tapitans believed the property belonged to them, given their prior residence on the site. Tensions escalated, culminating in threats made by Eleno Tapitan against Candia. On that day, a confrontation led to Candia being shot.
Sequence of Events and Shooting
Eyewitness Cleto Baranda described the encounter in detail, noting that Eleno Tapitan approached with a revolver and a bolo, challenging the deceased and Baranda about their presence on the land. Despite their pleas for a peaceful discussion, Eleno commanded his son Enriquito to shoot, resulting in multiple shots being fired. Baranda witnessed Enriquito firing a homemade shotgun from behind a banana grove before he was able to reload. The fatal shot struck Candia, who had raised his hands in a non-confrontational manner, indicating his intent to flee.
Medical Findings
The forensic examination of Candia revealed multiple gunshot wounds, including two wounds that significantly compromised vital organs, ultimately leading to death due to hemorrhage from the injuries. Both defendants acknowledged the reality of Candia's death but sought to escape liability through an alibi and a claim of self-defense.
Alibi Defense and Credibility Issues
The appellants claimed they were in Ozamis City on the day of the shooting, supported by the testimony of a witness, Maximo Leonardo. However, the trial court found this alibi unconvincing due to its implausibility, especially in contrast to the testimonies of Cleto Baranda and other witnesses present during the shooting. Notably, the defense's claim lacked substantial corroboration, which contributed to the court's doubt regarding its veracity.
Evaluation of Conspiracy and Conviction
The court evaluated whether the actions of Eleno and Enriquito Tapitan constituted a conspiracy to commit murder. The records indicated collaboration between them in attacking the deceased; thus, the trial court properly inferred a conspiracy. The Court of Appeals noted that once a conspiracy was shown, each conspirator is liable for actions taken in furtherance of that conspiracy, regardless of their individual participation level.
Judicial Findings and Sentence
The appellate court upheld the lower court's conviction of the Tapitan defendants for murder, identifying evident premeditation a
...continue readingCase Syllabus (G.R. No. L-21492)
Case Overview
- The case involves the conviction for murder of Enriquito Tapitan and Eleno Tapitan, father and son, stemming from the death of Maximo Candia.
- The incident occurred on April 9, 1958, in Goliptoc, Dumingag, Zamboanga del Sur, amidst a land dispute.
- The lower court sentenced the appellants to death, while a co-accused, Precioso Tapitan, received a lesser penalty due to mitigating circumstances.
Background of the Incident
- Maximo Candia and Cleto Baranda were co-purchasers of land from a certain Subano, intending to build a house.
- The Tapitan family claimed ownership of the same land, with a house belonging to Eleno Tapitan already erected there.
- Previous attempts at peaceful resolution failed, and threats were made by Eleno Tapitan against Candia.
Description of the Event
- On the morning of the incident, Cleto Baranda, the lone eyewitness, recounted seeing Eleno Tapitan armed with a revolver and bolo.
- Eleno confronted Candia and Baranda, refusing to discuss the matter peacefully and inciting violence.
- Enriquito Tapitan fired the first shot using a homemade shotgun from