PEOPLE v. HENRY SALVERON

FACTS:

On May 22, 1981, Gloria de Felipe was allegedly robbed and raped by Raul Salveron, Jesus Dalida, Mauricio Dumangas, and several others. Salveron was later shot to death during the trial in 1982, while Dalida was killed under mysterious circumstances. Dumangas survived an attack and accused Rosibal de Felipe, Marianito Billones Jr., and Jessie Vito of attempting to kill him.

Rosibal de Felipe was killed on March 26, 1986, in Barangay Dolores, Municipality of Balasan, Iloilo. Henry Salveron and Federico Sadava were implicated in Rosibal's murder. Victoriano Gregorio testified that he saw Henry Salveron and Federico Sadava at the foot of the bridge in Barangay Dolores shortly before the gunshots that killed Rosibal. Gregorio witnessed Salveron standing at the bridge with a firearm after he heard the gunshots.

An autopsy revealed that Rosibal died from gunshot wounds caused by a high-powered firearm. Captain Nicanorito Gomez, the station commander of the Integrated National Police branch in Balasan, testified that Salveron and Sadava were found positive for gunpowder residue during a paraffin test.

Salveron claimed alibi and stated that he had been on his uncle's farm in Anilao at the time of the killing. However, Judge Ricardo P. Galvez of the Regional Trial Court of Iloilo City acquitted Sadava for lack of evidence of conspiracy but found Salveron guilty and convicted him of murder. Salveron appeals this decision, arguing that the trial court erred in assuming his motive in killing Rosibal, his flight to Anilao, and the significance of the nitrate burns on his hands.

ISSUES:

  1. Whether the trial court erred in assuming that the appellant had a motive in killing Rosibal de Felipe

  2. Whether the trial court erred in considering the flight of the appellant after the killing as evidence of guilt

  3. Whether the trial court erred in considering the nitrate burns on the appellant's hands as evidence of guilt

RULING:

  1. The trial court did not err in its assumptions and findings. The testimony of Victoriano Gregorio, the star witness, corroborated by other evidence, established the appellant's guilt. Gregorio saw the appellant with a rifle moments after gunshots were heard and Rosibal de Felipe was found dead. The assumptions made by the trial court were merely corroborative of the principal evidence presented by the prosecution. Thus, the appellant's objections are without merit.

PRINCIPLES:

  • Corroborative evidence strengthens the credibility of the principal evidence in a criminal case.

  • Flight after the commission of a crime may be considered as evidence of guilt.

  • Physical evidence, such as nitrate burns, may be used to support the prosecution's case and establish guilt.