GR 27046 27047; (March, 1981) (Digest)
G.R. No. L-27046 and L-27047 March 30, 1981
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. MARIANO ESTEBAN Y MOLINA and LUIS CAMAYA Y ROCHA, accused-appellants.
FACTS
On May 1, 1963, Antonio Maravilla went to collect a debt from accused-appellants Mariano Esteban and Luis Camaya, stemming from a prior compromise over a homicide case. An altercation ensued. Later that evening, Maravilla was drinking with companions in a yard enclosed by a mat and coconut leaves. At around 11:00 PM, successive gunshots were fired at the group. Maravilla was wounded, and Maria Pascua, who was sleeping inside the adjacent house, was mortally hit. Maravilla, though seriously injured, managed to identify Esteban and another companion (Tomas Ablola) at the scene to responding policemen, both immediately after the shooting and in a subsequent dying declaration at the hospital.
ISSUE
The core issue is whether the guilt of both accused, Mariano Esteban and Luis Camaya, for the crimes of murder and frustrated murder was proven beyond reasonable doubt.
RULING
The Supreme Court acquitted Luis Camaya but affirmed the conviction of Mariano Esteban with modifications. For Camaya, the evidence was insufficient. His implication rested primarily on Maravilla’s identification made months after the incident via photograph, which the Court found lacked the immediacy and reliability of the declarations made against Esteban. There was no other substantial evidence linking Camaya directly to the shooting.
For Esteban, his guilt was established beyond reasonable doubt. The Court upheld the trial court’s findings, giving full credence to Maravilla’s positive and consistent identifications. These included his spontaneous statements to police at the scene and his detailed dying declaration at the hospital, which qualified as part of the res gestae. The Court rejected the defense of alibi and noted the corroborative paraffin test on Esteban. The killing of Maria Pascua constituted murder qualified by treachery, as she was shot while asleep, with dwelling as an aggravating circumstance. The shooting of Maravilla constituted frustrated murder. Applying the rules on aberratio ictus, Esteban was liable for the death of Pascua even if Maravilla was the intended victim. The death penalty was commuted to reclusion perpetua for murder, and an indeterminate sentence was imposed for frustrated murder. Indemnities were also increased.