People v. Lising
REITERATIONFacts
The Antecedents: Rodolfo Manalili, seeking to effect the arrest of Robert Herrera for the killing of his brother, Delfin Manalili, hired Felimon Garcia to find individuals who could carry out the task. Garcia contacted Roberto Lising, a policeman, who agreed to the job for P50,000.00, receiving P2,000.00 as down payment. Lising, along with Enrico Dizon and Robin Manga, conducted surveillance and abducted Ernesto Bernabe II (Cochise) and Ana Lourdes Castaños (Beebom) from Dayrit's Ham and Burger House in Quezon City on April 25, 1990. The victims were taken to a warehouse in San Fernando, Pampanga, owned by Ligaya Fausto, Lising's live-in partner. There, Cochise was stabbed to death by Garcia and Lising, and Beebom was subsequently killed. Their bodies were exhumed two months later. Procedural History: The accused were charged with Carnapping (R.A. 6539) and Kidnapping with Double Murder. During the trial, the prosecution presented eyewitnesses Froilan Olimpia (who witnessed the abduction) and Raul Morales (who testified on the killing). The accused, including Lising, Manalili, Garcia, Dizon, and Manga, presented defenses, including alibis and claims of coercion in their extrajudicial statements. The Regional Trial Court found Rodolfo Manalili, Roberto Lising, Felimon Garcia, Robin Manga, and Enrico Dizon guilty beyond reasonable doubt of Double Murder qualified by treachery and aggravated by evident premeditation and abuse of public position (for Lising, Manga, and Dizon). They were sentenced to double reclusion perpetua. Lising, Dizon, and Manga were also found guilty of Slight Illegal Detention aggravated by the use of a motor vehicle. Ligaya Fausto was acquitted. The Petition: The accused appealed their conviction, raising issues regarding the admissibility of extrajudicial statements, the credibility of witnesses, the existence of conspiracy, and the sufficiency of evidence.
Issue(s)
Whether the extrajudicial statements of the accused are admissible as evidence against them and their co-accused. Whether the testimonies of prosecution witnesses Froilan Olimpia and Raul Morales are credible. Whether conspiracy was established among the accused. Whether the accused are guilty of Kidnapping with Double Murder and Carnapping. Whether the defenses of alibi and coercion are tenable.
Ruling
The Supreme Court affirmed the conviction of Rodolfo Manalili, Roberto Lising, Felimon Garcia, Robin Manga, and Enrico Dizon for Double Murder, sentencing each to suffer the penalty of double reclusion perpetua. The Court also modified the conviction for Slight Illegal Detention to Kidnapping under Article 267(4) of the Revised Penal Code, sentencing the accused Lising, Dizon, and Manga to suffer the penalty of reclusion perpetua. The acquittal of Ligaya Fausto was affirmed. The conviction for Carnapping was set aside by the trial court and not appealed by the prosecution.
Ratio Decidendi
On the admissibility of extrajudicial statements: The Court held that extrajudicial statements are admissible against their declarants. The statements of Manalili and Garcia were voluntary and executed with counsel. Lising's claim of coercion was unsubstantiated, with evidence of voluntariness such as detailed facts unknown to investigators and counsel's signature. The Court also recognized the exception of "interlocking confessions" where independently executed statements are identical in material details, corroborating each other and serving as circumstantial evidence against implicated co-accused. On the credibility of witnesses: The Court gave full faith and credit to the testimonies of eyewitnesses Froilan Olimpia and Raul Morales, as found by the trial court, which is in a better position to assess credibility. Inconsistencies in minor details of Morales' testimony (e.g., order of car entry, exact location of killing) were deemed not to impair his credibility and even strengthened it by negating a rehearsed testimony. His initial reluctance to volunteer information due to fear was also considered understandable and common. On the existence of conspiracy: The Court found that conspiracy was established by the interlocking confessions and the concerted actions of the accused. The agreement to abduct and kill for a fee, the stake-out, abduction, detention, and subsequent killings demonstrated a unity of purpose and design. The acts of the accused, from hatching the plan to disposing of the bodies, pointed to a joint purpose and community of interest, making the act of one conspirator the act of all. On the guilt for Double Murder and Kidnapping: The Court affirmed the conviction for Double Murder based on the credible testimonies and interlocking confessions. The Court modified the conviction for Slight Illegal Detention to Serious Illegal Detention (Kidnapping) under Article 267(4) of the Revised Penal Code, considering the involvement of a female victim and the deprivation of liberty for an extended period. The Court noted that while Manalili and Garcia were not convicted of kidnapping by the trial court, they would still suffer reclusion perpetua for the double murder, and double jeopardy prevented their conviction for kidnapping on appeal. On the defenses of alibi and coercion: The Court found the alibis of Lising, Dizon, and Manga to be unconvincing and unsubstantiated. Lising's claim of coercion in his statement was rejected due to lack of evidence and presence of indicia of voluntariness. Manalili's defense of having hired the accused for a "legal arrest" was deemed preposterous, given the clandestine nature of the meetings, the abduction, and the subsequent killings, which indicated a sinister plot beyond a mere arrest.
Main Doctrine
Conspiracy is a unity of purpose and intention in the commission of a crime. Where two or more persons come to an agreement concerning the commission of a felony and decide to commit it, then conspiracy exists. The act of one conspirator is the act of all. Inconsistencies in minor details of a witness's testimony do not necessarily impair credibility and may even strengthen it by negating a rehearsed testimony. Extrajudicial statements, if voluntary and corroborated, are admissible and can be the basis for conviction.