G.R. No. L-3635; June 29, 1951
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ADRIANO MAPALAD and CELESTINO MAPALAD, defendants-appellants.

FACTS

On November 7, 1949, at about 6:30 p.m. in barrio Bato, Guindulman, Bohol, Claudio Deliso was walking home with Eugenio Ligtas when two men hidden behind a coconut tree successively clubbed him. He received two fatal blows: one to the forehead fracturing his skull and another to the nape. He died immediately. The attack was sudden. The prosecution’s evidence on identity consisted of: (1) For Celestino Mapalad, the testimony of eyewitness Eugenio Ligtas alone. (2) For Adriano Mapalad, Ligtas’s testimony plus Adriano’s extrajudicial confession, his plea of guilty at the preliminary investigation, and other admissions. Ligtas testified that Adriano struck first on the forehead, followed by Celestino on the neck. He recognized them as fellow barrio inhabitants, the area was an open thoroughfare, and there was light from a nearby lamparilla. He reported the incident only on November 10, explaining he feared reprisal due to bitter political animosity between the parties. The defendants presented alibis, claiming they were at their respective homes at the time, but the trial court rejected these. Adriano’s confessions and admissions were detailed: he gave a sworn statement ratified before the justice of the peace, pleaded guilty initially, led police to the recovery of the club used, identified it, and admitted a jacket found near the body was his. He alleged maltreatment by police, but the court found this unsupported, noting Celestino made no incriminating statements yet was not maltreated. The motive was political rivalry (Nacionalista vs. Liberal Party) exacerbated by prior personal enmity from a court case. On appeal, the defendants also challenged the validity of the preliminary investigation.

ISSUE

The main issue is the identity of the assailants. Subsidiarily, whether the trial was void due to an alleged lack of proper preliminary investigation.

RULING

The Supreme Court affirmed the conviction. The identity of both appellants as the assailants was established beyond reasonable doubt. For Celestino, Eugenio Ligtas’s testimony was credible and reliable given the circumstances of recognition. For Adriano, Ligtas’s testimony was corroborated by his own conclusive confessions and admissions, which contained factual details and were voluntarily given. The court found Ligtas’s delay in reporting explained by reasonable fear. The alibis were properly rejected. The claim of a defective preliminary investigation was waived, as defense counsel expressly stated satisfaction with the proceedings before the justice of the peace after the trial judge offered to conduct a new one. The crime was murder qualified by treachery. No aggravating or mitigating circumstances attended, so reclusion perpetua was proper. The indemnity was increased to P6,000, payable jointly and severally by the defendants.