Title
People vs. Zulkifli
Case
G.R. No. 233839
Decision Date
Dec 2, 2021
2003 Awang Airport bombing case: Zulkifli, Rifqi, and Pareja convicted for conspiracy; Delos Reyes acquitted. Penalties modified, damages awarded per RA 9346.
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Case Summary (G.R. No. 172370)

Facts of the Case

On February 20, 2003, an explosion occurred at the Awang Airport, resulting in one fatality and multiple injuries, as well as damage to property. The explosive device, an Improvised Explosive Device (IED), was placed in a vehicle parked near a restaurant by the airport. The prosecution filed an Information for murder and multiple frustrated murders against several individuals, with subsequent amendments to include additional suspects. While some accused were apprehended, others remained at large.

Version of the Prosecution

The prosecution presented a compelling narrative supported by the testimonies of five key witnesses, including Abdulgani, a former co-accused turned state witness. Their testimonies indicated that Zulkifli convened meetings to plan the bombing, with aims to disrupt a ceasefire between the government and the Moro Islamic Liberation Front (MILF). The specific roles of each accused were delineated during these meetings. The successful bombing on February 20 followed a prior failed attempt due to technical issues. Eyewitness accounts corroborated the involvement of various accused individuals, particularly implicating Zulkifli and Rifqi as central figures in the conspiracy.

Version of the Defense

The accused presented defenses predominantly based on denial and alibi. Delos Reyes claimed to have been teaching at a madrasa at the time of the bombing, while Pareja asserted that he was in Quezon City, attending to a family matter. Rifqi denied all accusations of involvement in the bombing, stating he was engaged in other activities unrelated to the incident. Zulkifli maintained that he was under the custody of the MILF during the bombing, denying his presence at any meetings regarding the conspiracy.

RTC Ruling

On July 14, 2014, the Regional Trial Court found Zulkifli, Rifqi, Delos Reyes, and Pareja guilty of murder with multiple attempted murder. They received sentences of reclusion perpetua and were ordered to pay civil damages and indemnities to the victims' heirs, while a few others were acquitted due to insufficient evidence.

CA Ruling

The Court of Appeals upheld the decision of the RTC in their First Decision, affirming the conviction of Delos Reyes and Pareja while increasing the award for moral damages. The separate appeal by Zulkifli and Rifqi also resulted in affirmation of their conviction with similar modifications to damages. The CA based its decisions largely on the sufficiency of witness testimonies against the accused, finding their defenses of alibi and denial unconvincing.

Issue

The central issue presented to the Supreme Court was whether the Court of Appeals erred in convicting the accused-appellants fo

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