Case Summary (G.R. No. 127663)
Charges and Judicial Proceedings
Valdez faced two main charges: 1) Complex crime of Multiple Murder with Double Frustrated Murder and 2) Illegal Possession of Firearms and Ammunition. The Regional Trial Court after a trial found him guilty of both offenses, sentencing him to death for the murders and to reclusion perpetua for illegal possession of firearms.
Summary of Events
On the evening of September 17, 1995, victims Ramon Garcia, Jr., Jean Marie Garcia, Willy Acosta, Sandra Montano, William Montano, and Randy Tibule were en route to a wedding party. They encountered Valdez and accomplices, who opened fire on them without provocation, resulting in the immediate deaths of four individuals and severe injuries to two others.
Court's Findings
The trial court determined that Roland Valdez acted with evident premeditation and abuse of superior strength. It held that the attack was executed in a treacherous manner, leaving the victims with no chance to defend themselves. The victims had sustained fatal injuries from gunshot wounds, corroborated by medical testimony during the trial.
Accused's Appeal and Claims
Valdez filed an appeal against the trial court's judgment, raising several claims, including discrepancies in witness testimonies, mistaken identity, failure to present police witnesses, and lack of proven motive for his actions.
Review of Evidence and Testimonies
The Supreme Court reviewed witness accounts, including those of William Montano and Randy Tibule, who identified Valdez as one of the perpetrators. Despite challenges regarding witness recantations and discrepancies in statements, the court found consistent identification of Valdez corroborated by other evidence, such as bullet shell recovery and the attack's nature.
Aggravating Circumstances
The trial court appreciated treachery in the execution of the crimes, recognizing no opportunity for the victims to retaliate. However, upon review, the Supreme Court found evidence lacked sufficient grounds to establish "evident premeditation." The rule clarifying the absence of aggravating circumstances when one is already qualified by treachery was considered.
Ruling on Sentences
In addressing the nature of the crime, the Supreme Court found that Valdez was not guilty of a complex crime but rather of four separate counts of murder and two counts of frustrated murder. Consequently, the sentence was modified to four consecutive sentences of reclusion perpetua for the murders and indeterminate sentences for the frustrated murders, recognizing that the earlier classification of the crime was erroneous.
Illegal Posse
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Case Overview
- The case involves accused-appellant Rolando Valdez, who sought the reversal of his conviction by the Regional Trial Court of Pangasinan for multiple serious offenses including multiple murder and illegal possession of firearms.
- The trial court's decision was rendered on October 24, 1996, sentencing Valdez to death for the complex crime of Multiple Murder with Double Frustrated Murder and imprisonment of reclusion perpetua for Illegal Possession of Firearms.
- The events took place on the evening of September 17, 1995, in Sitio Cabaoangan, Barangay Nalsian, Manaoag, Pangasinan.
Charges and Context
- The Information for Multiple Murder with Double Frustrated Murder detailed a conspiracy among Valdez and his accomplices to kill the victims while they were on a tricycle.
- The charge of Illegal Possession of Firearms stated that Valdez possessed a caliber .30 carbine without the necessary license.
- The prosecution provided evidence of the victims’ identities and the injuries sustained during the attack, which resulted in the deaths of four individuals and serious injuries to two others.
Evidence Presented
- The prosecution's evidence included eyewitness testimonies and medical examinations documenting the injuries of the deceased and survivors.
- Eyewitness accounts identified Valdez as one of the assailants who opened fire on the victims.
- The trial court noted the physical evidence, including bullet shells at the crime scene, supporting the claim of multiple shooters.
Trial Court's Findings
- The trial court found Valdez guilty bey