G.R. No. L-3396; April 18, 1951
The People of the Philippines, plaintiff-appellee, vs. Iglicerio Muñoz and Narciso Andal, defendants-appellants.

FACTS

On the evening of March 27, 1949, Arturo Salandanan was sitting by the threshold of his brother Julian’s warehouse in barrio Cabay, Tiaong, Quezon, watching a generator when he was shot. After the gunfire ceased, Julian found Arturo wounded. Arturo told Julian that Iglicerio Muñoz shot him and that another unidentified man also fired from the east. Witness Juanito Maranan testified he saw Iglicerio Muñoz and Narciso Andal, both armed with carbines, pass by and later saw Iglicerio firing at Arturo from about five meters away, with additional shots coming from a mango tree. Witness Leon Javier testified he heard Iglicerio and Narciso, after the shooting, conversing that Arturo was surely the one they shot. The prosecution presented evidence of motive: Iglicerio was in love with the same girl Arturo was courting and had previously threatened Arturo; about a month prior, Julian had disarmed Iglicerio and Narciso during a confrontation, turning a pistol over to the mayor. Arturo died from hemorrhage while being transported to the hospital after being treated by Dr. Quinio. The defense presented alibis: Iglicerio claimed he attended an all-night vigil, and Narciso claimed he was in an adjoining barrio husking nuts and then attending a baptismal party from dusk until the afternoon of the next day. The defense also alleged that Julian Salandanan was a brigand and was incriminating them because they refused to join his banditry and instead joined a volunteer guard organization. The trial court convicted both appellants of murder.

ISSUE

The primary issue is whether the trial court erred in convicting the appellants of murder based on the evidence presented, including the admissibility of the victim’s dying declaration and the credibility of the defense’s alibi and allegations against the prosecution witness.

RULING

The Supreme Court affirmed the judgment of the trial court. The identity of Iglicerio Muñoz and Narciso Andal as the killers was fully established through the positive testimonies of eyewitnesses Juanito Maranan and Leon Javier. The Court held that the statement of Arturo Salandanan to his brother identifying Iglicerio as the shooter was admissible as a dying declaration, as the circumstances (his grave gunshot wound, request to be taken to the hospital, and subsequent death during transport) fairly indicated his consciousness of impending death. The defense of alibi was rejected as highly improbable and could not prevail over the positive identification by credible witnesses. The Court found no merit in the defense’s insinuation that the prosecution witnesses were coerced, noting the delay in signing affidavits was reasonably explained and they affirmed their testimonies in court. The allegation that Julian Salandanan was a brigand was not substantiated by any criminal complaints; instead, evidence showed he was an estate administrator and property owner. The crime was murder qualified by treachery, and the penalty of reclusion perpetua was in accordance with law.