Case Summary (G.R. No. 98468)
Charges and Proceedings
The accused were charged with murder under Article 248 of the Revised Penal Code, based on allegations they conspired to kill the victim armed with a homemade shotgun, exhibiting evident premeditation and treachery. During arraignment, both pleaded not guilty. The trial court acquitted Armando Villanueva, finding no evidence of conspiracy or direct involvement; however, Rogino Villanueva was found guilty beyond reasonable doubt and sentenced to reclusion perpetua, along with an indemnity to the victim's heirs.
Evidence Presented
Key evidence presented by the prosecution included testimonies describing the events leading to the murder. Witnesses, including Venancio Tabobo, recounted that both accused had approached Joselito Itona while Rogino carried a pugakhang. Rogino shot Joselito at close range from behind, resulting in the victim's immediate death due to serious gunshot wounds, confirmed during an autopsy performed the following day.
Defense Assertions
Rogino Villanueva's defense was based on an alibi, asserting he was gathering tuba two kilometers away at the time of the incident. He testified about the demands of his occupation, claiming he spent significant portions of his day climbing coconut trees to gather juice.
Trial Court's Findings
The trial court rejected Rogino’s alibi, citing inadequate evidence to support his claim. The testimonies from the prosecution witnesses were found credible and consistent, asserting Rogino's presence at the crime scene during the incident. The court emphasized the precision of the witnesses in identifying both accused and noted the absence of corroborative evidence supporting the alibi.
Appellate Review
On appeal, Rogino maintained that the trial court erred in concluding that his guilt was proven beyond reasonable doubt. The appellate court reiterated that factual findings by the lower court, particularly regarding witness credibility, are generally upheld unless there is a significant misapprehension of evidence.
Evaluation of the Defense
The appellate court underscored that for alibi to be effective, it must demonstrate impossibility of presence at the crime scene during the incident. Rogino’s defense primarily relied on denials devoid of corroborative evidence, failing to meet the strict standard necessary to establish an alibi. Moreover, the identity of both accused in the shooting was firmly established by multiple eyewitness accounts.
Treachery and Sentencing
The court confirmed that the murder was executed with treachery as Rogino ambushe
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Case Background
- The case concerns the murder charge against Armando Villanueva and Rogino Villanueva, alias "Digoy," for the death of Joselito Itona on November 15, 1986, in Cauayan, Negros Occidental.
- The charge stated that both accused conspired and aided each other, armed with a homemade shotgun (pugakhang), intending to kill with evident premeditation and treachery.
- During the arraignment, both accused pleaded not guilty.
Trial Court Proceedings
- The Regional Trial Court acquitted Armando Villanueva, citing insufficient evidence of conspiracy and linking him to the crime.
- Rogino Villanueva was found guilty of murder beyond reasonable doubt and sentenced to reclusion perpetua, along with an indemnity of P30,000 to the victim's heirs.
Prosecution's Evidence
- The prosecution established a timeline indicating that at approximately 6:30 PM, Joselito Itona and Venancio Tabobo were conversing in front of Itona's residence when Rogino Villanueva approached with a shotgun and shot Joselito in the back.
- Witness Ismael Banson observed Rogino carrying the weapon and saw the shooting occur.
- The medical examination confirmed that Joselito Itona suffered fatal injuries from the shotgun wounds.
- Both accused were arrested shortly after the incide