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PEOPLE v. BONIFACIO RADA

FACTS:

The accused-appellants, Bonifacio Rada and Adriano Sacdalan, were charged with Multiple Murder before the Regional Trial Court. It was alleged that on September 19, 1989, in Barangay Vinas, Municipality of Calauag, Province of Quezon, the accused, armed with firearms, attacked and shot Simeon Castillo, Isidro Castillo, and Leonora Castillo, causing their deaths. The accused were charged with murder qualified by treachery.

During the trial, Dr. Winefredo Lucido, the Municipal Health Officer of Calauag, testified that he conducted post mortem examinations on the cadavers of Isidro Castillo and Simeon Castillo. The autopsy showed that Isidro Castillo sustained a gunshot wound that resulted in massive hemorrhage and caused his death. Simeon Castillo sustained five gunshot wounds, including a skull fracture and massive hemorrhage, which also caused his death.

Juanito Castillo, son of the victims, testified that he was awakened by loud gunfire coming from his parents' house and was later informed by his sister that his father and brother were dead. His mother, Leonora, who was wounded, told him that the accused-appellants were responsible for the killings. Afraid for their lives, Juanito cautioned his relatives not to reveal the identities of the assailants. He brought his mother to the hospital, but she died before receiving treatment. Juanito also testified that his parents were killed because they witnessed the earlier killing of a neighbor by the accused-appellants and that the accused-appellants had been pressuring his brother, Simeon, to reveal the whereabouts of a brother-in-law who is a member of the NPA.

The case involves the killing of Leonora Castillo on September 19, 1989 in Vinas, Calauag, Quezon. The prosecution presented several witnesses to establish the events leading to Leonora's death. Isidro Castillo, husband of Leonora, testified that on the night of the incident, he heard someone knocking and calling his daughter's name, followed by stones being thrown at their house. He heard gunshots and saw his son Simeon fall down. Two armed men, identified as accused-appellants Bonifacio Rada and Adriano Sacdalan, entered their house. Aida Castillo, daughter-in-law of Isidro and Leonora, also testified and corroborated the events. She saw her husband being shot and pleaded for the accused-appellants to stop. Zenaida Lopez Castillo, granddaughter of Isidro and Leonora, was also present during the incident and witnessed the events. She identified the accused-appellants and heard her grandmother repeatedly mention their names. Dr. Zadi Zaballero, a physician at the hospital, testified on the injuries sustained by Leonora, which caused her death. The defense, on the other hand, presented witnesses who claimed to be with accused-appellants at the time of the incident. Sgt. Jolly Verde testified that they were resting at a house in a different barangay when they heard gunshots and proceeded to investigate.

ISSUES:

  1. Whether or not the guilt of the accused-appellants, Bonifacio Rada and Adriano Sacdalan, was proven beyond reasonable doubt.

  2. Whether or not the dying declaration of Leonora Castillo identifying the accused-appellants as the perpetrators is admissible.

  3. Whether treachery was sufficiently established to qualify the crime as murder.

RULING:

  1. The Supreme Court found no reason to disturb the trial court's findings and conclusions, affirming that the prosecution successfully established the guilt of the accused-appellants beyond reasonable doubt through the positive identification by eyewitnesses Aida Castillo and Zenaida Castillo.

  2. The dying declaration of Leonora Castillo was deemed admissible. The Court considered it as an ante mortem statement, as it was made in a serious condition and was deemed reliable.

  3. The Court agreed with the trial court in appreciating treachery in the commission of the crime. The manner in which the attack was carried out, which left the victims defenseless, was indicative of treachery.

PRINCIPLES:

  1. Credibility of Witnesses: Minor inconsistencies in the testimonies of witnesses do not necessarily impair their credibility but may even enhance their authenticity.

  2. Dying Declaration: Statements made by a person on the verge of death, regarding who inflicted the injuries, are considered highly reliable and admissible as evidence.

  3. Treachery: Treachery is present when the means employed in committing the crime ensures its execution without risk to the assailant due to the surprise element, leaving the victim defenseless.

  4. Alibi and Denial: Alibi and denial are weak defenses when faced with positive identification by credible witnesses. For an alibi to be valid, the accused must demonstrate that it was physically impossible for them to be present at the crime scene.

  5. Initial Reluctance to Report: Witnesses' initial reluctance to report a crime due to fear of reprisal is not unusual and does not affect their credibility.