People v. Nardo
REITERATIONFacts
The Antecedents: On July 21, 1985, accused-appellants Edwin Nardo and Willy Ylarde went to the eatery of spouses Claro and Micaela Suitos, offering to sell marijuana. Claro Suitos refused, stating it was prohibited. Later that evening, Nardo and Ylarde returned to the eatery and fired indiscriminately with an M16 Armalite rifle and a short firearm, respectively. The shooting resulted in the death of Clarence Suitos, Anicia Sales, Macario dela Peña, and Luzviminda Pudol, and the wounding of Claro Suitos and Micaela Suitos. A third victim, Marivic Suitos, sustained a slight wound. Procedural History: Accused Nardo was initially charged with multiple murder with double frustrated murder. Accused Ylarde was later charged via an amended information for the same crime. The Regional Trial Court of Tayug, Pangasinan, convicted both accused of multiple murder with double frustrated murder and sentenced them to reclusion perpetua. The court also ordered them to pay damages to the heirs of the deceased and the injured parties. The Petition: Accused-appellants appealed their conviction, arguing that the prosecution's evidence was weak and unconvincing, and that their defense of alibi should have been given more weight. They specifically assailed the credibility of eyewitnesses Micaela Suitos and Rogelio Fernandez.
Issue(s)
Whether the trial court erred in convicting the accused based on the prosecution's evidence, despite the defense of alibi. Whether the crime committed was a complex crime of multiple murder with double frustrated murder, or separate crimes of murder and attempted murder. Whether the qualifying circumstance of treachery was present. Whether the injuries sustained by Micaela and Claro Suitos constituted frustrated murder or attempted murder.
Ruling
The Supreme Court affirmed the conviction of the accused-appellants but modified the crime committed. It ruled that the accused were guilty of four separate crimes of murder and two separate crimes of attempted murder, not a complex crime. The penalties imposed were four terms of reclusion perpetua for the murders and two indeterminate sentences for the attempted murders. The monetary awards for damages were affirmed.
Ratio Decidendi
On the credibility of witnesses and sufficiency of evidence: The Court reiterated the rule that findings of fact by the trial court, particularly on the credibility of witnesses, are entitled to great respect and are generally considered correct. The trial court did not overlook any substantial fact that could affect the outcome. The positive identification of the accused by eyewitnesses Micaela Suitos and Rogelio Fernandez, who had no apparent motive to falsely implicate the appellants, outweighed the defense of alibi. Micaela Suitos, a victim herself and relative of other victims, provided unwavering testimony despite cross-examination. The initial reluctance of witnesses to come forward due to fear of reprisal does not diminish their credibility. The Court also noted that sworn statements taken ex-parte are inferior to testimony given in open court, and that Micaela Suitos was likely in shock during the initial police investigation. On the nature of the crimes committed: The Court ruled that the crime was not a complex crime of multiple murder with double frustrated murder. Article 48 of the Revised Penal Code defines a complex crime as when a single act constitutes two or more grave or less grave felonies, or when one offense is a necessary means to commit another. The autopsy reports showed that each fatality sustained a gunshot wound, and eyewitness testimony indicated separate discharges of firearms by both accused. Therefore, the killing of four victims and wounding of two others from separate shots constituted four separate crimes of murder and two separate crimes of attempted murder, not a single complex crime. The Court held that the information, while charging a complex crime, effectively imputed several felonies, and the appellants' failure to move to quash the information constituted a waiver, allowing the Court to rule on all proven crimes. On the qualifying circumstance of treachery: The Court found that the attack was sudden and unexpected, without provocation, giving the victims no opportunity to defend themselves. This qualified the murders with treachery, as the victims were unaware of the impending aggression and had no chance to seek cover, resist, or retaliate. On the classification of injuries sustained by Spouses Suitos: The Court determined that while Spouses Micaela and Claro Suitos were injured, there was no proof adduced regarding the extent and gravity of their injuries to establish that they would have died had medical attention not been given. Consequently, the offenses against them were classified as attempted murder, not frustrated murder.
Main Doctrine
The Supreme Court affirmed the conviction of the accused but modified the crime committed from a complex crime of multiple murder with double frustrated murder to four separate crimes of murder and two separate crimes of attempted murder, emphasizing that separate shots resulting in multiple deaths and injuries constitute distinct offenses. The Court also reiterated the rule on giving great respect to the findings of fact of the trial court regarding the credibility of witnesses.