Case Summary (G.R. No. 237721)
Facts of the Case
On the evening of November 14, 1951, an armed force entered Tiaong, Quezon. They burned Mayor Punzalan’s residence (₱23,023 loss), Valentin Robles’s house (₱10,000 loss), another dwelling, and two Chinese stores. Three persons were killed, six wounded, and looting occurred. Reinforcements under Captain Alzate eventually dispersed the raiders.
Pre‐Raid Political Conflict
Umali and Punzalan, once allies, became rivals over local political influence. In the 1951 mayoral election, Umali supported Pasumbal against incumbent Punzalan. Campaign rhetoric grew vitriolic, with threats of violence prophesied by Umali (“blood will flow,” “golden coffin”) and mutual accusations of corruption and ineffectiveness.
Planning and Execution of the Raid
Star witness Amado Mendoza testified that on November 12, 1951, Umali instructed Pasumbal to enlist Huk dissidents led by Commander Abeng to eliminate Punzalan. After Punzalan’s overwhelming election victory on November 13, some fifty Huks, guided by Pasumbal and Capino, attacked Tiaong the next night. They divided forces: one group fired on the local Army camp as diversion, while the main contingent stormed Punzalan’s house with automatic weapons, grenades, and petrol bombs.
Roles of Umali, Pasumbal, and Capino
Pasumbal and Capino personally negotiated with Huk commanders, met dissidents at the town’s edge, and engaged in the assault on Punzalan’s property. Umali’s participation was established by Mendoza’s testimony—Umali ordered the Huk contact—and corroborated by circumstantial evidence placing him, armed, near the scene before fleeing toward Taguan.
Trial Court Findings and Appellants’ Defense
The trial court found the three guilty of the complex crime of rebellion with multiple murder, frustrated murder, arson, and robbery, imposing life imprisonment and indemnities totaling over ₱63,000. Appellants claimed alibis in Taguan, asserted they were merely at a post‐election gathering, and argued non‐participation in the raid.
Criminal Responsibility and Appellate Court Ruling
The Supreme Court affirmed conviction. It found Government witnesses credible, rejected Mendoza’s late retraction, and held appellants’ evasive conduct (flight, avoidance of Tiaong, inconsistent statements) indicative of guilt. The Court declined to decide the existence of a “complex crime” doctrine, opting to convict on separate offenses charg
Case Syllabus (G.R. No. 237721)
Procedural History
- Trial before the Court of First Instance of Quezon Province, finding appellants guilty of the complex crime of rebellion with multiple murder, frustrated murder, arson and robbery
- Sentenced to life imprisonment, accessory penalties, and joint indemnities to numerous victims
- Direct appeal by Narciso Umali, Epifanio Pasumbal and Isidro Capino to the Supreme Court
Subject of Appeal
- Challenge to conviction for a complex crime comprising rebellion, multiple murder, arson, robbery, and frustrated murder
- Request to review sufficiency of evidence and legal characterization of offenses
- Question as to appellants’ criminal responsibility, degree of participation, and credibility of witnesses
Facts of the Case
- Night raid on the town of Tiaong, Quezon, between 8:00 and 9:00 p.m. on November 14, 1951
- Destruction by fire of Mayor Marcial Punzalan’s house and two other residences, with combined property damage valued over ₱23,000
- Deaths of Patrolman Domingo Pisigan and civilians Vicente Soriano and Leocadio Untalan
- Wounding of Patrolman Pedro Lacorte and five civilians; subsequent looting of one house and two Chinese stores
- Dispersal of raiders by Captain Alzate and local military forces
Political Relations and Conflict
- Longstanding personal and political alliance between Congressman Narciso Umali and Mayor Marcial Punzalan, deteriorating after mutual jealousy and factional accusations
- 1947: Umali campaigns for Punzalan’s mayoralty; 1949: Punzalan supports Umali’s congressional bid
- By 1950, mutual distrust leading to allegations of recruiting local policemen into Huk ranks and intervention to secure their surrender
- Mutual filing of complaints; strained communications and antagonism by mid-1951
Pre-Election Campaign and Tensions
- November 13, 1951 elections in Tiaong, Punzalan runs for re-election, opposed by Pasumbal under Umali’s direction
- Intense, bitter, and sometimes violent political meetings featuring personal attacks, threats of bloodshed, and promises of “golden coffin” for Punzalan
- Drafting of Amado Mendoza as campaign orator and aide to Umali and Pasumbal
Conspiracy with Hukbalahap
- November 12, 1951: Umali instructs Pasumbal to contact Huk Commander Abeng for Punzalan’s assassination
- Pasumbal’s mountain conference with Commander Abeng, witnessed by Huk member Nazario Anonuevo
- Plans to po