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PEOPLE v. GREGORIO MEJIA Y VILLAFANIA

FACTS:

In the evening of March 10, 1994, along the expressway at Barangay Ventinilla, Sta. Barbara, Pangasinan, several individuals aboard a passenger jeepney driven by Teofilo Landingin attacked him and one of the passengers, Virgilio Catugas, inflicting multiple stab wounds on both victims. Landingin was forcibly removed from his seat and left on the roadside, while Catugas was thrown onto the road as the jeepney was driven away by one of the attackers. Consequently, Landingin succumbed to his injuries and died, while Catugas survived.

Following the incident, Gregorio Mejia, Edwin Benito, Pedro Paraan, Joseph Fabito, Romulo Calimquim, an individual identified only as Dennis, Alex Mamaril, an individual referred to as Mondragon, and one unidentified person were implicated. Mejia and Benito were apprehended by the police within hours of the incident, Paraan on the following day, and Fabito five days later. Calimquim was found dead three days after the incident, and the remaining suspects remained at large. In connection with this incident, three separate criminal complaints were filed against the accused for murder, frustrated murder, and violation of the Anti-Carnapping Act of 1992 (R.A. No. 6539).

Despite being served with subpoenas to submit counter-affidavits, Mejia, Benito, Paraan, and Fabito failed to comply, leading Judge Lilia C. Espanol to declare on May 9, 1994, that the accused waived their right to a preliminary investigation. The judge found a prima facie case against them and recommended formal charges and prosecution for the above-mentioned crimes. Consequently, the Office of the Provincial Prosecutor of Pangasinan filed three separate informations for murder, frustrated murder, and violation of the Anti-Carnapping Act with the Regional Trial Court (RTC) of Dagupan City, which were respectively docketed as Criminal Cases Nos. 94-00617-D, 94-00619-D, and 94-00620-D. The first information was subsequently amended.

Criminal Cases Nos. 94-00617-D and 94-00619-D were assigned to Branch 44 of the RTC of Dagupan City, presided over by Judge Crispin C. Laron, and later consolidated for a joint trial. Criminal Case No. 94-00620-D was assigned to Branch 43, presided by Judge Silverio Q. Castillo. Mejia, Benito, Paraan, and Fabito all pleaded not guilty at their arraignment.

ISSUES:

  1. Whether the appellants Gregorio Mejia, Edwin Benito, Pedro Paraan, and Joseph Fabito are guilty of the crimes of murder, frustrated murder, and violation of the Anti-Carnapping Act of 1972.

RULING:

  1. The Supreme Court REVERSED the decisions of the lower courts. It acquitted Gregorio Mejia, Edwin Benito, Pedro Paraan, and Joseph Fabito of the crimes of murder, frustrated murder, and violation of the Anti-Carnapping Act of 1972 on the ground that the guilt of the appellants was not proved beyond reasonable doubt or with moral certainty.

PRINCIPLES:

  1. Presumption of Innocence: The accused are presumed innocent until proven guilty beyond reasonable doubt. This principle mandates that unless the prosecution successfully discharges its burden of proof, the accused must be acquitted.

  2. Proof Beyond Reasonable Doubt: Guilt must be established beyond reasonable doubt to convict an accused. The evidence against the accused must survive the test of reason, and strong suspicion should not sway the judgment.

  3. Absence of Conspiracy: Mere association or presence at the scene does not establish conspiracy. Conclusive evidence linking the accused to the group committing the crime is required.

  4. Trustworthiness of Testimony: The credibility of key witnesses is crucial. The testimony of a witness must be clear, consistent, and devoid of ulterior motives to be reliable.

  5. Compromise and Admissions: Offers to settle or reimburse expenses do not equate to an admission of guilt, especially in the absence of authorization by the accused or evidence showing such compromise as an implied admission of guilt.

  6. Entries in Police Blotters: These are not given undue significance as they can be incomplete or inaccurate, not necessarily reflecting the declarations made by the accused.