G.R. No. L-5199 October 29, 1953
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. TRINIDAD SADAVA, defendant-appellant.

FACTS

On June 13, 1946, in barrio Callejon, Tiaong, Quezon, Valeriano Caraig and Apolinar Hernandez were searching for a medicine man. While returning, they met the appellant Trinidad Sadava (carrying an automatic carbine), his brother Jose Sadava, and brother-in-law Francisco Mendoza (both carrying long firearms). After a brief conversation between Apolinar and the appellant, the groups separated. Shortly after, Francisco Mendoza shot Valeriano from behind, hitting him in the right lumbar region. As Valeriano fell, more shots were fired. The three armed assailants then fled. Macario Sandoval and Valentin Basilan, working nearby, heard the shots and saw the appellant and his companions fleeing. They found Valeriano wounded, who identified his assailants as the appellant and his two companions before being taken home where he died hours later from internal hemorrhage. The appellant, along with Francisco Mendoza and Jose Sadava, was charged with murder. At trial, the defense presented an alibi, claiming the appellant was at the police headquarters in San Juan, Batangas, five to six kilometers away, for security reasons on the nights of June 11, 12, and the morning of June 13, 1946, supported by a police blotter entry and testimony from Sgt. Mercado. The defense also claimed the shooting was an affray between Valeriano’s group and a group including Jose Sadava and Francisco Mendoza, but not the appellant. The trial court convicted the appellant of murder, considering the mitigating circumstances of fear of serious injury and resentment analogous to passion and obfuscation, and sentenced him to an indeterminate penalty. The appellant appealed.

ISSUE

The main issue is whether the trial court erred in convicting the appellant of murder based on the evidence presented, despite his defense of alibi and challenges to the credibility of prosecution witnesses.

RULING

The Supreme Court affirmed the conviction but modified the penalty. The Court found no reason to reverse the trial court’s findings. The positive testimonies of prosecution witnesses Apolinar Hernandez, Macario Sandoval, and Valentin Basilan, who personally witnessed the events or their immediate aftermath, established the appellant’s presence and participation. The appellant’s defense of alibi could not prevail over this positive identification, especially since the distance from San Juan, Batangas to the crime scene could be traversed in one hour by walking, and the police blotter did not conclusively prove he never left the headquarters. The Court also found that the appellant, along with his two armed companions, acted in conspiracy, making him equally liable as a principal even if he did not fire the fatal shot. The alleged inconsistencies in the witnesses’ statements were deemed minor and not fatal. The Court rejected the application of Amnesty Proclamation No. 76, as the appellant failed to register under its terms and there was no showing the crime was among those specified. The Supreme Court held that the trial court erred in appreciating the mitigating circumstances of fear of serious injury and passion and obfuscation, as the deceased victim was not shown to have participated in the alleged threats that provoked the appellant. In the absence of any mitigating or aggravating circumstances, the proper penalty for murder is reclusion perpetua. The Court modified the sentence accordingly and affirmed the appellant’s solidary liability for the full indemnity of P6,000 to the heirs of the deceased.