G.R. No. 233839, December 02, 2021
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. ZULKIFLI/JULKIFLI @ DONIS/DONI OFRACIO/AHMAD FAISAL, TAUFIQ RIFQI, ET AL., ACCUSED; ZULKIFLI/JULKIFLI @ DONIS/DONI OFRACIO/AHMAD FAISAL, TAUFIQ RIFQI, FELICIANO DELOS REYES @ BOX, AND DINNO AMOR R. PAREJA @ KHALEEL, ACCUSED-APPELLANTS.

FACTS

The case stemmed from the bombing of the Awang Airport in Barangay Awang, Datu Odin Sinsuat, Maguindanao, on February 20, 2003, at around 2:30 p.m. An Improvised Explosive Device (IED) placed in a white Suzuki Multicab parked near a restaurant across the airport’s entrance gate exploded, resulting in one fatality (Sgt. Nelson Corpuz), multiple injuries (including victims Haydee Bello and Luna Umpal), damage to the terminal building, and burned houses. The original Information for Murder with Multiple Frustrated Murder was filed against Hadji Hamid Zulhamid and Joseph Madaran, and was subsequently amended several times to include other accused, ultimately charging appellants Zulkifli, Taufiq Rifqi, Feliciano Delos Reyes, and Dinno Amor Pareja, among others.
The prosecution’s case, based on the collective testimonies of five witnesses including accused-turned-state-witness Sammy Abdulgani, established that in early February 2003, appellant Zulkifli, an Indonesian Jemaah Islamiyah member, convened a meeting at a safehouse in Cotabato City with MILF members, including Abdulgani, to plan the bombing. The aim was to terminate the ceasefire between the government and the MILF. The plan involved using a multicab to carry the bomb. In a second meeting, appellants Rifqi, Delos Reyes, and Pareja, members of a balik Islam group, joined and were assigned to transport the bomb and act as passengers. An initial attempt on February 19, 2003, failed due to a wet blasting cap. On February 20, 2003, after surveillance, Abdul Nasser Kitogi parked the bomb-laden multicab near the Pampangueña restaurant. Abdulgani and Ibrahim Kessel entered the restaurant while the balik Islam members remained in the vehicle. As the balik Islam members began to alight, Kitogi activated the bomb and fled with Abdulgani on a motorcycle. The explosion followed, killing Sgt. Corpuz and injuring others.
Among the numerous accused, only some were apprehended. Appellants Delos Reyes and Pareja were arraigned on January 24, 2006, and appellants Zulkifli and Rifqi were arraigned on May 4, 2012. All pleaded not guilty. The Regional Trial Court (RTC) of Pasig City, Branch 154, convicted them in a Decision dated July 14, 2014. The Court of Appeals (CA) affirmed the RTC’s decision through two separate Decisions: the First Decision dated April 28, 2016, pertaining to Delos Reyes and Pareja, and the Second Decision dated March 30, 2017, pertaining to Zulkifli and Rifqi. The appellants filed separate appeals.

ISSUE

The core issue is whether the guilt of accused-appellants Zulkifli, Rifqi, Delos Reyes, and Pareja for the crime of Murder with Multiple Frustrated Murder was proven beyond reasonable doubt.

RULING

The Supreme Court denied the appeals and affirmed the convictions. The Court found that the prosecution successfully established the existence of a conspiracy among all appellants to carry out the bombing. The detailed testimony of state witness Abdulgani, which was found credible and corroborated by other evidence, clearly narrated the planning meetings, the assigned roles (with Zulkifli and Rifqi as planners/bomb experts and Delos Reyes and Pareja as part of the transport/execution team), the failed first attempt, and the successful execution on February 20, 2003. Their collective and coordinated actions, from planning to detonation, demonstrated a unity of purpose and design. The crime was qualified by treachery as the mode of attack—using a concealed bomb in a parked vehicle—ensured the victims had no opportunity to defend themselves. The aggravating circumstance of use of a motor vehicle was also present. The Court upheld the findings of fact of the RTC and the CA, emphasizing that the credibility of witnesses is best determined by the trial court. The defenses of denial and alibi raised by the appellants were deemed weak and unsubstantiated compared to the positive identification and detailed account provided by the prosecution witness.