GR 110515; (July, 2000) (Digest)
G.R. No. 110515; July 18, 2000
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. VALENTIN MATIBAG y ALDAY and WENCESLAO CASTILLO y ABITRIA, accused-appellants.
FACTS
On November 8, 1990, Atty. Rufino Carlos was shot and killed inside his parked car in Lucena City. His wife witnessed the incident. The investigation, later joined by the NBI, identified inmate Valentin Matibag as the gunman through eyewitness identification. Matibag, in a statement, confessed to the killing, claiming he was released from the Quezon Provincial Jail and ordered by Provincial Jail Warden Eligio Bautista to commit the murder for a P50,000.00 reward, with assistance from other jail personnel.
Ballistic examination of firearms from jail personnel revealed that the seven empty shells recovered at the crime scene were fired from a Colt .45 pistol with Serial No. 81811, which was the service firearm officially issued to Assistant Provincial Warden Wenceslao Castillo. Matibag and his co-accused, including Castillo, pleaded not guilty, denying the charges and claiming their extrajudicial confessions were coerced. The trial court convicted Matibag and Castillo of murder.
ISSUE
Whether the guilt of accused-appellants Valentin Matibag and Wenceslao Castillo for the crime of murder was proven beyond reasonable doubt.
RULING
Yes, the Supreme Court affirmed the conviction. The Court upheld the trial court’s assessment of the evidence, particularly the credibility of Matibag’s extrajudicial confession and the ballistic findings. The confession was deemed voluntary, as Matibag failed to substantiate his claim of coercion with clear and convincing evidence. The detailed narration of the conspiracy, including the planning, the reward, and the execution, indicated its reliability.
Crucially, the ballistic report conclusively established that the shells from the crime scene were fired from Castillo’s service firearm, Serial No. 81811. This physical evidence directly linked Castillo to the crime and corroborated Matibag’s confession regarding the use of that specific weapon. The Court rejected the defense of alibi and found the elements of murder, qualified by evident premeditation, to be present. The conspiracy was evident from the coordinated actions of the accused in planning the killing, releasing Matibag, providing the weapon, and carrying out the ambush. The penalty of reclusion perpetua was affirmed. The Court modified the civil liability, ruling that the accused-appellants are jointly and severally liable for P50,000.00 as death indemnity, not P50,000.00 each.