Case Summary (G.R. No. L-39075)
Facts of the Case
On the morning of August 10, 1969, Nicomedes Garcia, age twenty-three, was ambushed and killed by gunfire in the vicinity of Pasong Lagarian while on his way back from the market. The postmortem examination revealed six entrance wounds, indicating that he was shot from a distance by a carbine. Eyewitness Priscila Garcia-Poniente, Nicomedes' sister, testified that she and her father witnessed the ambush performed by Tibayan, who was subsequently identified as the shooter. Witness accounts, including those of Mamerto Garcia, Nicomedes' father, corroborated that there had been an altercation between Nicomedes and Tibayan prior to the shooting.
Witness Testimony and Investigation
The main eyewitness, Priscila, described her experience in detail. She and her father hid in bushes when they spotted Tibayan and another suspect, Cesar de la Rea, who were armed and apparently lying in wait. After observing the shooting, which resulted in Nicomedes falling from his horse, Priscila immediately went home to inform the family about the incident. Initially, the family refrained from immediately reporting Tibayan due to fear of retaliation. However, they later provided sworn statements to the authorities, leading to formal charges being filed against Tibayan on September 22, 1969, long after the initial investigation.
The Preliminary Investigation
Following the filing of the murder complaint, the preliminary investigation revealed various contradicting testimonies from both the prosecution and defense witnesses. Despite some witnesses trying to absolve Tibayan, significant evidence was gathered, including statements from the Garcia family that placed Tibayan at the scene of the crime. The municipal judge found probable cause to issue a warrant for Tibayan's arrest, which happened nearly eleven months after the incident.
Trial Proceedings
The trial began with extensive cross-examination of the eyewitness. The prosecution argued that the evidence presented demonstrated beyond reasonable doubt Tibayan's involvement in the murder. In contrast, the defense presented an alibi and witnesses attempting to challenge the credibility of the prosecution’s witnesses. Notably, issues arose from the non-appearance of Tibayan's counsel during a critical hearing, which the trial court interpreted as a waiver to present further evidence.
Verdict and Sentencing
Ultimately, the trial court rendered a decision on July 9, 1974, convicting Tibayan of murder. The court found that the testimonies of Priscila and Mamerto Garcia were credible and supported by evidence that contradicted the defense's claims. Tibayan was sentenced to reclusion perpetua and ordered to pay damages to the victim's estate.
Appellate Considerations
Tibayan subsequently appealed, asserting that he was denied due process due to the trial court's ruling on
...continue readingCase Syllabus (G.R. No. L-39075)
Case Overview
- The case involves the appeal of Redentor Tibayan from the decision of the Court of First Instance of Cavite, which convicted him of murder.
- Tibayan was sentenced to reclusion perpetua and ordered to pay indemnity and moral damages to the heirs of the victim, Nicomedes Garcia.
- The crime occurred on August 10, 1969, when Nicomedes Garcia was ambushed and shot to death.
Incident Details
- The incident took place around 6:30 AM in Pasong Lagarian, near Barrios Minantok and Bucal, Amadeo, Cavite.
- A postmortem examination revealed that Nicomedes sustained six gunshot wounds, confirming he was shot with a carbine while facing the assailant at a distance, as indicated by the absence of powder burns.
Eyewitness Account
- Priscila Garcia-Poniente, the only eyewitness and younger sister of the victim, testified about the events leading to and following the shooting.
- Priscila, accompanied by her father Mamerto, observed Redentor Tibayan and Cesar de la Rea waiting to ambush someone.
- Upon seeing Nicomedes approach, Tibayan fired at him, causing him to fall from his horse.
Victim's Family Reaction
- Following the incident, Priscila and Mamerto were