Case Summary (G.R. No. 95751-52)
Applicable Law
The applicable law in this case is primarily derived from the 1987 Philippine Constitution, as the decision date is in 1990. The relevant statutes concerning murder, the parameters for conviction, and the standards of evidence are invoked in this criminal proceeding.
Procedural Background
The prosecution filed Informations against the appellants, accusing them of murder under Criminal Case Nos. 15-88 and 16-88. Following their arraignment on November 29, 1988, where they entered pleas of not guilty, the trial commenced. The prosecution presented several witnesses, including Lorenzo Miguel, who provided critical testimony.
Prosecution's Evidence
The prosecution’s case relied heavily on the eyewitness testimony of Lorenzo Miguel, who observed the ambush of Atty. Madrid and Umoso. Miguel detailed how he witnessed the events unfold, including recognizing the appellants. His account described the setting and actions of both defendants during the commission of the crime, contributing significant evidence of their guilt.
Defense's Claims
The appellants asserted defenses of alibi and denial, claiming they were engaged in official duties and had no involvement in the crime. They presented their sworn statements denying participation and suggested that the killings were orchestrated by another party—specifically, they insinuated involvement by the New People's Army (NPA).
Trial Court's Findings
The Regional Trial Court found the prosecution's evidence sufficient for conviction, emphasizing the credibility of Lorenzo Miguel despite the defense's arguments questioning his impartiality and character. The court ruled that the positive identification and corroborating circumstances against the appellants justified their convictions.
Key Issues on Appeal
The appellants raised several issues on appeal, challenging the sufficiency of evidence, the credibility of witness Miguel, the trial judge's reliance on said testimony, and the implications of motive. They asserted that the trial judge erred in convictions that relied solely on witness testimony without corroboration.
Court's Rationale on Appeal
The Appellate Court evaluated the credibility of Lorenzo Miguel's testimony against claims of bias and delay in his statements, ultimately affirming his reliability as a witness. The court found that delays in reporting did not detract from his credibility and maintained that the evidence presented supported a consistent narrative of the events leadi
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Case Overview
- The case concerns the appeal of Jaime Tumaru and Alex Maun against their convictions for the murder of Atty. Eduardo Madrid and Santiago Umoso.
- The case was decided by the Third Division of the Supreme Court of the Philippines on December 2, 1999, under G.R. No. 95751-52.
Background of the Case
- The criminal proceedings were initiated with Informations filed on September 13, 1988, by 1st Assistant Provincial Fiscal Godofredo G. Guerrero.
- In Criminal Case No. 15-88, Tumaru and Maun were accused of killing Atty. Eduardo Madrid on May 24, 1987, in Malubibit, Flora, Kalinga-Apayao.
- In Criminal Case No. 16-88, they were similarly charged with the murder of Santiago Umoso on the same date and location.
- The prosecution alleged the presence of treachery, evident premeditation, and ignominy in the commission of the crimes.
Proceedings and Evidence Presented
- The accused entered negative pleas on November 29, 1988, and a joint trial commenced.
- The prosecution presented multiple witnesses including Lorenzo Miguel, Zenaida Madrid (widow of Atty. Madrid), and Dr. Ferdinand Nicolas, among others.
- Lorenzo Miguel testified to witnessing the incident, describing how he saw Atty. Madrid and Umoso ambushed while riding a motorcycle.
Witness Testimonies
- Lorenzo Miguel's Testimony:
- Described seeing a man signal him from a tree, later identified as Alex Maun.
- Witnessed Atty. Madrid and Umoso being shot at close range.
- Identified Tumaru and Maun in a police