G.R. No. 115985 -86; August 31, 2000
People of the Philippines, plaintiff-appellee, vs. Allan Jarandilla, accused-appellant.

FACTS

On February 10, 1991, in Barotac Viejo, Iloilo, appellant Allan Jarandilla, a policeman, rode a jeep with victims Nilo Prieto (driver), Bonifacio Jalandoni, and Peter Paul Aldeguer. While the jeep was ascending a hill, multiple gunshots were fired. Aldeguer was killed, and Prieto and Jalandoni were seriously wounded. The P20,000 Aldeguer had won at a cockfight was missing. Jarandilla was the sole unharmed passenger. Prieto and Jalandoni positively identified Jarandilla as the assailant who shot them from behind. The defense presented alibi and denial, claiming another person committed the crimes, and presented ballistics evidence that the fatal bullets did not come from Jarandilla’s service firearm.
The Regional Trial Court convicted Jarandilla of Double Frustrated Murder for the shootings of Prieto and Jalandoni, and Robbery with Homicide for the killing of Aldeguer and the taking of his money. Jarandilla appealed, arguing the prosecution failed to prove his guilt beyond reasonable doubt and questioning the credibility of the eyewitnesses.

ISSUE

The core issue is whether the prosecution proved the guilt of appellant Allan Jarandilla for the crimes charged beyond reasonable doubt.

RULING

Yes, the Supreme Court affirmed the conviction but modified the crimes and penalties. The Court upheld the trial court’s assessment of the eyewitnesses’ credibility. Both Prieto and Jalandoni gave consistent, straightforward, and categorical testimonies identifying Jarandilla as the shooter. Their testimonies were corroborated by medical findings that the victims were shot from behind, indicating treachery. The defense of denial and alibi cannot prevail over positive identification. The ballistics report, which showed the bullets did not match Jarandilla’s service firearm, was deemed inconclusive as it did not preclude the use of another gun.
However, the Court corrected the legal characterization of the crimes. For Jalandoni, who tested positive for powder burns indicating he was shot at close range, the crime is Attempted Murder, not Frustrated Murder, as the prosecution did not prove the wound was fatal. For Prieto, shot from behind without powder burns, the crime is correctly Frustrated Murder with treachery. For Aldeguer, the complex crime of Robbery with Homicide was upheld, as the killing occurred on the occasion of the robbery. The penalties and awarded damages were modified accordingly.