G.R. No. L-30304 June 7, 1971
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. PRIMITIVO PERALTA, ET AL., defendants, PEDRO PILLOS, defendant-appellant.

FACTS

On October 15, 1967, Fortunato Daquioag, an NP mayoral candidate in Marcos, Ilocos Norte, was shot and killed while riding in a jeep that passed by a political meeting for his opponent, incumbent Mayor Primitivo Peralta. The jeep’s driver, Norberto Macatiag, was also wounded. The incident led to murder and frustrated murder charges against Mayor Peralta, Chief of Police Pedro Pillos, and Patrolmen Jose Rosal and Amando Arios. The prosecution’s narrative established that as the jeep slowly passed the meeting place, Pillos and Rosal flagged it down, ran after it, and boarded it. Pillos, positioned near the front seat, demanded to know if the occupants were armed. Upon receiving a negative reply, Patrolman Rosal, clinging to the jeep’s side, shot Daquioag in the head. As Daquioag slumped, Chief Pillos then fired, hitting him in the body. The jeep fled, with shots being fired at it as it departed.
The defense presented a starkly different account, claiming self-defense. They alleged that when Pillos discovered a carbine under a seat, Daquioag drew a gun and aimed it at him. Patrolman Rosal, seeing his chief in peril, fired at Daquioag. The trial court convicted Pedro Pillos and Jose Rosal, sentencing them to life imprisonment for murder and an indeterminate penalty for frustrated murder. Pillos alone appealed, arguing the evidence was insufficient to convict him while acquitting his co-accused Peralta and Arios.

ISSUE

The core issue is whether the evidence presented by the prosecution sufficiently establishes the guilt of appellant Pedro Pillos for the crimes of murder and frustrated murder beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction. The Court upheld the trial court’s assessment of witness credibility, giving greater weight to the testimony of disinterested eyewitness PC Corporal Victorio Campos, who corroborated the prosecution’s version that Pillos fired the fatal shot after Daquioag was already incapacitated by Rosal’s initial gunfire. The necropsy report, indicating two distinct bullet entry wounds from different directions, materially supported this sequence of events. The legal logic rests on the principle that factual findings of the trial court, especially regarding credibility of witnesses, are accorded high respect and are generally binding on appeal unless substantial facts were overlooked.
The Court found no merit in Pillos’s claim of inconsistent evidence merely because Mayor Peralta was acquitted. Criminal liability is personal, and the acquittal of one co-accused based on lack of evidence of conspiracy does not absolve another whose direct participation was proven. The evidence concretely established that Pillos, by boarding the moving vehicle, confronting the occupants, and firing his weapon, directly participated in the attack. His actions, following Rosal’s initial shots which rendered Daquioag defenseless, constituted a deliberate and concerted attack qualifying the killing as murder. The affirmed penalties and indemnities were thus deemed appropriate.