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PEOPLE v. ABUNDIO ROLUNA

FACTS:

In 1990, eight individuals, namely Abundio Roluna, Carlos Daguing, Paterno Daguing, Mamerto Asmolo, Teodulfo Daguing, Federico Simpron, Bienvenido Simpron, and Didoc Bongcalos, were charged with the crime of Kidnapping with Murder before the Regional Trial Court in Baybay, Leyte. The charge stemmed from an incident that allegedly occurred on May 27, 1984, wherein the accused conspired and kidnapped Anatalio Moronia, subsequently killing him. Only accused Abundio Roluna was apprehended, tried, and convicted, while the other seven remained at large.

At the trial, the prosecution presented witnesses Conrado Sombilon and Buenaventura Nogalada. Sombilon testified that on the day of the incident, he saw Roluna and seven other individuals, armed with firearms, hogtie and kidnap Moronia. Nogalada corroborated Sombilon's testimony, stating that he witnessed Moronia with his hands tied behind his back being led by Roluna and others. Both witnesses testified that Moronia was never seen or heard from after the incident.

On the other hand, Roluna claimed that he was not involved in the crime and presented an alibi defense. He stated that during the time of the incident, he was attending to his wife's bedridden grandmother in another barangay. Roluna's alibi was supported by his wife and his grandmother-in-law. Roluna argued that the prosecution witnesses harbored ill-feelings toward him and falsely implicated him in Moronia's disappearance. He cited past disputes he had with the witnesses as the basis for their grudges against him.

After the trial, the court found Abundio Roluna guilty beyond reasonable doubt of Kidnapping with Murder, imposing the penalty of life imprisonment or reclusion perpetua. Roluna appealed the decision.

ISSUES:

  1. Whether the prosecution was able to prove the guilt of the accused beyond reasonable doubt.

  2. Whether the corpus delicti was duly proved by the prosecution.

RULING:

  1. The Supreme Court affirmed the trial court's finding of guilt beyond reasonable doubt. The testimonies of the prosecution witnesses, Sombilon and Nogalada, were consistent and corroborated each other. Their eyewitness accounts of the kidnapping were clear and detailed. The defense of denial and alibi posed by the accused was weak as it was not supported by credible evidence. The court found no reason to doubt the credibility of the prosecution witnesses and their testimonies were sufficient to establish the guilt of the accused.

  2. The corpus delicti, which refers to the body or substance of the crime, was sufficiently proved by the prosecution. While the body of the victim was never found, the witnesses testified on the circumstances surrounding the kidnapping and the subsequent disappearance of the victim. The testimonies provided a clear picture of the crime committed and the involvement of the accused.

PRINCIPLES:

  • The guilt of the accused must be proven beyond reasonable doubt.

  • Eyewitness testimonies, when credible and corroborated, can be sufficient evidence to establish guilt.

  • The corpus delicti can be established even without the physical body of the victim, as long as there is sufficient evidence to prove the crime committed.