GR 116600; (July, 1996) (Digest)
G.R. No. 116600 July 3, 1996
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. M/SGT. REYNALDO LANDICHO, PAT. JOHNNY BUNYI, C1C ERIC MANLUSOC, and C2C LEOVINO CANUEL, accused.
FACTS
The accused, all members of the Philippine National Police (PNP), were charged with the murder of Isagani Mazon in Calapan, Oriental Mindoro, on January 8, 1991. The information alleged they conspired and attacked the victim with firearms, inflicting twenty-one gunshot wounds. Upon surrender, the trial court, granting their motion, ordered their detention at the PNP Stockade instead of the provincial jail, with the strict condition that they were not to leave without a court order. Despite this, reports reached the trial court that the accused were seen outside the stockade on multiple occasions, including traveling to Batangas and attending a cockfight, allegedly under escort by fellow PNP personnel. Only appellant Landicho was subsequently arrested and tried after his co-accused remained at large.
ISSUE
The core issue is whether the prosecution proved the guilt of appellant Reynaldo Landicho for the crime of murder beyond reasonable doubt.
RULING
Yes. The Supreme Court affirmed the conviction. The Court found the testimony of eyewitness Lolita Mazon, the victim’s wife, to be credible and sufficient to establish Landicho’s criminal liability. She positively identified Landicho as one of the armed men who forcibly took her husband from their home and later heard gunshots. Her testimony was consistent and withstood rigorous cross-examination. The Court rejected the defense of alibi, noting it was weak and uncorroborated. The flight of Landicho’s co-accused and their repeated unauthorized departures from detention, facilitated by their PNP colleagues, further reinforced a consciousness of guilt. The qualifying circumstance of treachery was duly proven, as the attack was sudden and deliberate, rendering the victim defenseless. The Court emphasized the grave abuse of authority and the betrayal of public trust exhibited by the accused law enforcers. The decision of the trial court was thus affirmed in toto, with modifications to the civil indemnity.