G.R. No. L-34036, November 29, 1983
The People of the Philippines, Plaintiff-Appellee, v. Diego Estrada, Juanito Estrada and Luis Estrada, Defendants, Diego Estrada, Defendant-Appellant.

FACTS

A complaint for Murder was filed against Diego, Juanito, and Luis Estrada for the death of Romeo Escurel. After their arrest and waiver of preliminary investigation, the case was elevated to the Court of First Instance. An assistant provincial fiscal moved for its provisional dismissal, believing insufficient evidence for conviction, and the accused were released. The case was later revived with the filing of a Murder information. Only Diego Estrada was tried, as his co-accused evaded arrest. The trial court convicted Diego Estrada of Murder, sentencing him to reclusion perpetua.
The prosecution evidence established that on August 9, 1967, in Gubat, Sorsogon, the victim, Romeo Escurel, was initially assaulted by Luis Estrada and others after a drinking session. Later that evening, after Escurel sought police help, he was again attacked by Luis and another. Subsequently, eyewitness Espiridion Policarpio saw Diego, Luis, and Juanito Estrada, armed with clubs, beating Escurel, who then fled. The victim’s body was later found in a well. Diego Estrada gave a statement to police admitting he was fetched by his son Luis, who showed injuries from a fight, and that they later found Escurel, whom they confronted, after which Escurel fell into a well.

ISSUE

The primary issue is whether the trial court erred in convicting Diego Estrada of Murder based on the evidence presented, including the admissibility and probative value of his statement to police and the rejection of his alibi defense.

RULING

The Supreme Court affirmed the conviction. The Court held that Diego Estrada’s statement to the police, while not an explicit confession of guilt, contained admissions relevant to the crime—such as being summoned by his injured son, confronting the victim, and the victim subsequently falling into a well—which, when combined with other evidence, corroborated his participation. This circumstantial evidence, alongside the positive eyewitness identification placing him at the crime scene, sufficiently established his guilt.
The Court rejected the defense of alibi as weak and unpersuasive. Diego Estrada’s house was less than a kilometer from the crime scene, a distance easily negotiable, and his presence was attested to by multiple witnesses. Regarding qualifying circumstances, the Court found that the crime was committed with superiority of strength, as three armed men attacked a single, helpless victim, qualifying the killing as Murder. However, evident premeditation was not proven, as the attack appeared impulsive following Luis Estrada’s complaint about his injuries. With no mitigating or aggravating circumstances, the penalty of reclusion perpetua was appropriate. The trial court’s judgment was affirmed in its entirety.