G.R. No. L-16109 & L-16110; October 20, 1961
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ISABELO ALMIREZ and ISABELO PRINCIPE, defendants-appellants.

FACTS

The prosecution’s case, primarily through eyewitness Delfin Ursolino, established that on August 8, 1955, in Mauban, Quezon, appellants Isabelo Principe and Isabelo Almirez, along with Moises Impreso (at large), killed Crispin Santamena. Ursolino testified he was nearby when the three, armed with a rifle and carbines, summoned Santamena. Impreso ordered Principe to hack the victim and Almirez to stand guard. Principe complied, inflicting multiple fatal wounds, including a near-decapitating blow to the neck. The assailants, identified as members of the Hukbalahap, then fled. The victim’s body, bearing the described wounds and bruises indicating he had been tied, was later recovered. Florentino Santamena, the victim’s brother, and Wilfredo Malabagyo corroborated the motive by testifying that the appellants later approached Florentino, admitted to the killing, and warned him against reporting it.
Both appellants denied involvement, presenting alibis. Almirez claimed he was in a distant barrio during the incident, while Principe asserted he was in the Sierra Madre mountains in Laguna. They denied knowing the eyewitness or the victim’s brother and suggested the witnesses testified falsely due to personal grudges. Their witness, Engracio Bamba, claimed to have discovered the body but did not see the assailants.

ISSUE

Whether the appellants’ guilt for the crime of murder was proven beyond reasonable doubt, and whether the killing was committed in furtherance of the Huk rebellion, which would affect jurisdiction.

RULING

The Supreme Court affirmed the conviction for murder. The Court found the testimony of eyewitness Delfin Ursolino to be clear, positive, and credible, sufficiently establishing the appellants’ direct participation in the killing. His account was corroborated by the physical evidence and the testimonies of Florentino Santamena and Wilfredo Malabagyo regarding the appellants’ subsequent admission of guilt. The defenses of alibi were rightly rejected by the trial court for being weak and unsubstantiated, especially in the face of positive identification.
On the legal issue of jurisdiction, the appellants argued the crime was committed in furtherance of the Huk rebellion, which would place it under the jurisdiction of military tribunals under the doctrine of People vs. Geronimo. The prosecution’s own evidence included Ursolino’s testimony that the leader, Impreso, accused the victim of reporting the Huk camp to authorities before the killing. However, the Court held this insufficient to prove the crime was politically motivated. The victim had immediately denied the accusation, and, crucially, the appellants themselves never raised this defense at trial or presented evidence that they genuinely believed the victim was an informant. Since the burden to prove this jurisdictional fact lay with the defense and was not met, the Court of First Instance properly exercised jurisdiction. The qualifying circumstances of treachery and abuse of superior strength attended the crime, justifying the conviction for murder and the penalty of reclusion perpetua.