Case Summary (G.R. No. L-29118)
Incident Description
On the evening of April 29, 1964, Pablo Fernandez was outside his store fixing ropes for his carabao when he was shot multiple times with a shotgun. He was quickly transported to the Tayug Emergency Hospital, where he succumbed to extensive injuries, including internal and external hemorrhaging caused by the gunshots. A medical examination revealed multiple entry wounds to his back and exit wounds through his thorax and forearm.
Arrival of Authorities
Upon hearing the gunfire, Police Officer Emilio Calibo, a local resident, responded to the scene after being alerted by rural police. After gathering information that identified Artemio Turalba as the shooter, he and his colleagues went to the Turalba household. There they discovered Turalba’s shotgun, which had the distinct odor of gunpowder, suggesting recent use.
Initial Investigation
Turalba was taken voluntarily to the Constabulary headquarters for questioning, where he denied any involvement in the shooting. The next day, police gathered sworn statements from several witnesses—Nemesio and Ernesto Fernandez—who identified Turalba as the assailant. Additional witnesses corroborated these accounts, asserting that they had seen Turalba fleeing the scene with a shotgun.
Defense Testimony
In his defense, Turalba asserted that he was at a nearby store conversing with friends at the time of the shooting. However, no one corroborated his alibi, which was considered weak given the proximity to the crime scene. His account claimed he had returned home after hearing a shot and only became aware of the accusation against him upon being taken into custody several hours later.
Forensic Evidence
A paraffin test administered on Turalba’s hands returned negative for gunpowder residue. However, this evidence was deemed insufficient to establish his innocence since the possibility existed that he could have worn gloves or the test was done after a too-late interval. The prosecution posited that the negative result could not definitively exclude him as the shooter.
Trial Court Findings
The trial court assessed the testimonies of witnesses and concluded that these were credible despite minor inconsistencies. The court affirmed that Ernesto Fernandez and another witness had clearly identified Turalba as the individual who shot Pablo Fernandez. The court found Turalba guilty of murder, sentencing him to reclusion perpetua and requiring him to provide financial compensation to the victim's heirs.
Appeal and Issues of Credibility
On appeal, Turalba's counsel primarily challenged the credibility of the identification by the prosecution witnesses and asserted that the absence of gun ownership evidence weakened the case against him. However, the court held that the prosecution’s evidence of Turalba's guilt was overwhelming, noting that inconsistencies were not substantial enough to invalidate the identifications.
Motive and Circumstantial Evidence
The court considered evidence indicating a prior conflict between the Turalba family and the victim, establishing a potential motive for the murder. This conflict stemmed from a public altercation two years prior, further supporting the prosecut
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Case Overview
- Court: Supreme Court of the Philippines, Second Division
- Date of Decision: February 28, 1974
- G.R. No.: L-29118
- Parties: The People of the Philippines (Plaintiff and Appellee) vs. Artemio Turalba, Alias Arting (Defendant and Appellant)
Facts of the Case
- On April 29, 1964, at approximately 7:00 PM, Pablo Fernandez, a forty-eight-year-old barrio captain, was shot while at his store in Carosucan Sur, Asingan, Pangasinan.
- Fernandez was performing routine chores when he was struck by multiple gunshot wounds, leading to his immediate death at Tayug Emergency Hospital.
- The autopsy performed by Dr. Melquiades A. Bravo revealed the cause of death as "irreversible shock due to massive internal and external hemorrhage" from a shotgun blast, with multiple entry wounds on his back.
- Witnesses identified Artemio Turalba as the assailant, who was seen fleeing the scene with a shotgun.
- Turalba was apprehended when police officers visited his home and found a shotgun that smelled of gunpowder.
Investigation and Evidence
- Police investigation led to the collection of testimonies from family members of the victim, pointing to Turalba as the shooter.
- Turalba was interrogated and subjected to a paraffin test, which yielded negative results for gunpowder residue.
- Witnesses included Ernesto and Nemesio Fernandez (the victim's son and