GR 128181; (June, 1999) (Digest)
G.R. No. 128181. June 10, 1999.
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. BONIFACIO RADA and ADRIANO SACDALAN, accused-appellants.
FACTS
Accused-appellants Bonifacio Rada and Adriano Sacdalan, CAFGU members, were charged with Multiple Murder for the shooting deaths of Simeon, Isidro, and Leonora Castillo on September 19, 1989, in Calauag, Quezon. The prosecution established that at around 1:00 AM, the accused, armed with firearms, fired upon the victims’ house. Isidro and Leonora were inside their room, while Simeon was on the balcony. The attack continued as the accused entered the house and shot the already wounded Simeon despite pleas for mercy.
The prosecution’s case relied on the ante mortem statements of the fatally wounded Leonora Castillo, who identified Rada and Sacdalan as the assailants to her son, Juanito, both immediately after the shooting and while en route to the hospital. Medical testimony confirmed all three victims died from fatal gunshot wounds. The defense consisted of alibi and denial, claiming they were elsewhere at the time of the incident.
ISSUE
Whether the guilt of the accused-appellants for the crime of Murder was proven beyond reasonable doubt.
RULING
Yes, the Supreme Court affirmed the conviction. The trial court correctly appreciated the qualifying circumstance of treachery. The victims were attacked suddenly at night while inside their home—Isidro and Leonora were lying down, and Simeon was switching on a light. They were defenseless and given no opportunity to defend themselves or escape. The accused initially fired from outside the house to ensure no risk to themselves and then entered to finish off the wounded Simeon, confirming the deliberate execution of the attack.
The positive identification through the dying declaration of Leonora Castillo, received as part of the res gestae, prevails over the weak defenses of alibi and denial. For alibi to succeed, the accused must demonstrate the physical impossibility of their presence at the crime scene. The defense failed to do so, as their claimed location was merely two kilometers away. The Court also found no merit in the argument that the accused would not have committed the crime without concealing their identities, as the darkness of the late hour provided sufficient cover. The totality of evidence established conspiracy and guilt beyond reasonable doubt.