GR 239137; (December, 2018) (Digest)
G.R. No. 239137. December 05, 2018.
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. CEZAR CORTEZ AND FROILAN BAGAYAWA, ACCUSED, CEZAR CORTEZ, ACCUSED-APPELLANT.
FACTS
This case stemmed from the killing of five individuals—Mario Punzalan, Minda Punzalan, Efren Villanueva, Baby Mesina, and Jocelyn Mesina—at Minda’s Bakery in Angeles City on May 19, 1988. The prosecution’s case rested primarily on the eyewitness account of Janet Quiambao, who testified that she saw accused-appellant Cezar Cortez and his co-accused Froilan Bagayawa, who were bakers at the establishment, perpetrate the killings. Janet witnessed Cezar hit Mario with a rolling pin while he was asleep and later stab Minda. She also saw Froilan stab Efren. The assailants then entered the room where Janet, Baby, and Jocelyn were sleeping, stabbing the latter two to death, while Janet hid and survived. The testimony was corroborated by Richard Punzalan, a son of the owners who also hid during the incident, and Leonardo Punzalan, who reported the crime and noted Mario’s missing watch, later recovered from Froilan’s body after a police encounter. The case was archived after Cezar escaped initial apprehension but was revived upon his arrest in 2010.
In his defense, Cezar invoked denial and alibi, claiming he was working as a tinapa maker in Tarlac at the time of the incident and did not know the victims or his co-accused. He asserted he only learned of the charges upon his warrantless arrest in 2010. The Regional Trial Court convicted him not of the complex crime of Robbery with Multiple Homicide as charged, but found him guilty of two counts of Homicide for the deaths of Mario and Efren, and three counts of Murder for the deaths of Minda, Baby, and Jocelyn, the latter qualified by abuse of superior strength. The Court of Appeals affirmed the conviction but modified the classification of the crimes.
ISSUE
The core issue is whether the prosecution proved the guilt of accused-appellant Cezar Cortez beyond reasonable doubt for the killings, and whether the qualifying circumstances for Murder were correctly appreciated.
RULING
The Supreme Court affirmed the conviction but modified the penalties and awards. It upheld the factual findings of the lower courts, giving great weight to the positive identification by eyewitness Janet Quiambao, which was clear, consistent, and corroborated. The Court found her testimony more credible than the weak defenses of denial and alibi, which were unsubstantiated. The Court agreed that the prosecution failed to prove the robbery component, leading to separate convictions for the homicides.
On the classification, the Court applied the ruling in People v. Jugueta to standardize damages. It found that the killing of Efren Villanueva was correctly classified as Homicide, as no qualifying circumstance was proven. However, it ruled that the killings of Mario, Minda, Baby, and Jocelyn were all Murder, qualified by treachery. The attack on Mario while he was asleep ensured he had no opportunity to defend himself. The killings of Minda, Baby, and Jocelyn were similarly executed in a swift and sudden manner, rendering them defenseless. The Court imposed reclusion perpetua for each of the four counts of Murder and an indeterminate penalty for the single count of Homicide, with corresponding civil indemnity, moral, exemplary, and temperate damages plus interest.
