Title
People vs. Yurong
Case
G.R. No. L-39025
Decision Date
Oct 31, 1984
Ricardo Daligdig was shot dead in his home by intruders; wife Rufina identified Rodolfo Yurong and Felix Bahian. Alibi rejected, murder affirmed due to treachery and dwelling.

Case Summary (G.R. No. L-39025)

Summary of Charges

The prosecution alleged that the accused conspired to kill Ricardo Daligdig, using homemade shotguns, with the qualifying circumstances of treachery and evident premeditation. Consequently, the trial court sentenced Rodolfo Yurong and Felix Bahian to reclusion perpetua, along with ordering them to pay indemnities totaling P37,000 to the heirs of the victim, which reflected damages for death indemnity, loss of earning capacity, moral damages, and exemplary damages.

Circumstances of the Crime

On the night of the incident, after supper, Ricardo Daligdig was shot while investigating the barking of dogs outside his home. Following the shooting, witnesses described how Rufina Daligdig attempted to assist her husband before seeking help from neighbors. Eventually, she identified Yurong and Bahian as two of the assailants of her husband during her testimony.

Evidence and Testimonies

Rufina Daligdig testified that she recognized the two men who shot her husband, despite initially withholding their identities out of fear for her safety. After the victim's burial, she reported the incident to the National Bureau of Investigation (NBI) and identified Yurong and Bahian by name in a sworn affidavit.

Furthermore, a pivotal witness, Dionisio Martinez, corroborated Rufina's account, having seen both Yurong and Bahian on the night of the murder armed with shotguns and discussing their intention to harm Ricardo Daligdig.

Defense Arguments

Yurong and Bahian claimed alibi, asserting they were elsewhere at the time of the shooting. However, the court found their testimonies insufficient and inconsistent with the evidence presented. The defense also argued that the motive for killing Daligdig was not established; however, the trial court noted that motive is not strictly necessary for a murder conviction when identification of the accused is clear.

Ruling and Legal Considerations

The trial court established that the accused were guilty of murder, highlighting treachery and dwelling as qualifying circumstances. While the law provided for the death penalty for such an offense, the court ultimately sentenced the appellants to reclusion perpetua due

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