FACTS:

This case involves the accused being charged with multiple murder and attempted murder for the death of Florentino Dulay, Norwela Dulay, and Nissan Dulay, as well as the wounding of Noemi Dulay. The prosecution presented witness Ruben Meriales, who testified that on August 25, 1996, he was watching television with his family when his dogs barked. His mother, fearing that their cow might be stolen, asked him to check the disturbance. Meriales went outside and noticed barangay captain Jaime Carpo and Warlito Ibao stooping near his barn, with Warlito's son Roche standing by a mango tree. They were looking in the direction of Florentino Dulay's house. Meriales saw Oscar Ibao, another son of Warlito, walking towards Dulay's hut and observed him lift the sawali mat near the wall and throw something inside. Seconds later, an explosion occurred and Teresita Dulay, Florentino's wife, started screaming. Meriales went to Florentino's hut and saw the bloody scene. He left to borrow a jeepney to transport the victims to the hospital. Norwela, who had chest and lower appendage injuries, died on the way, while Nissan died later due to shrapnel wounds. Noemi survived but was taken to another hospital. Meriales refused to give a statement to the police initially but later named Jaime Carpo, Warlito Ibao, Oscar Ibao, and Roche Ibao as the perpetrators, saying that Florentino was killed because he was about to testify against Roche Ibao for the murder of his brother. A criminal complaint was filed against the accused based solely on Meriales' testimony, and they were subsequently arrested.

The accused, Jaime Carpo, Warlito Ibao, Oscar Ibao, and Roche Ibao, were charged and convicted of the multiple murder of Florentino Dulay, Norwela Dulay, and Nissan Dulay, as well as the attempted murder of Noemi Dulay. The incidents occurred on the night of August 25, 1996, when a hand grenade explosion took place at the Dulay hut in Brgy. Baligayan. The prosecution's main witness, Ruben Meriales, positively identified the accused as the perpetrators of the crime. Ruben testified that he saw the accused near the Dulay hut before the explosion. The defense, on the other hand, claimed alibi and denied any involvement in the incident. Jaime presented testimonies from himself and his wife, Veronica, stating that they were at home in a different barangay at the time of the explosion. Warlito, Oscar, and Roche claimed that they were having a farewell party for Maribel Ibao and did not hear the blast. Additionally, they argued that Ruben falsely implicated them due to a personal grudge. The trial court gave full credit to Ruben's testimony and consequently sentenced the accused to death. The case was elevated to the Supreme Court for automatic review. The accused later filed an addendum to their appellate brief, urging the admission of the results of their lie detector tests conducted by the NBI. However, the Supreme Court held that lie detector tests are not accepted as an accurate means of determining truth or deception and therefore disregarded the results.

ISSUES:

1. Whether the results of the accused's lie detector tests should be admitted as evidence.

2. Whether the testimony of Ruben Meriales is credible despite the alleged inconsistencies and his alleged resentment towards the accused.

3. Whether the defense of alibi raised by the accused is valid.

4. Whether the accused-appellants conspired in perpetrating the offense charged.

5. Whether the crime committed against Noemi Dulay should be denominated as attempted murder or multiple murder.

6. Whether the case falls under Art. 48 of The Revised Penal Code on complex crimes.

7. Whether the agreed amount of P600,000.00 as civil damages should be given force and effect.

8. Whether or not RA 7659, which prescribes the death penalty, is constitutional.

RULING:

1. The results of the accused's lie detector tests should not be admitted as evidence. The Court does not put credit and faith on the result of a lie detector test as it has not been accepted by the scientific community as an accurate means of ascertaining truth or deception.

2. The testimony of Ruben Meriales is deemed credible. The trial court is best equipped to make an assessment of witnesses, and its factual findings are generally not disturbed on appeal unless it has overlooked, misunderstood or disregarded important facts. Ruben's alleged inconsistencies are not material, and his admitted resentment against the accused should even be considered in his favor. His behavior of concealing himself behind the kitchen wall during the incident is also deemed understandable.

3. The defense of alibi raised by the accused is futile. The accused's proximity to the scene of the crime and the short amount of time it would take for them to be at the place of the incident undermine their alibi defense.

4. The trial court correctly ruled that accused-appellants conspired in perpetrating the offense charged. The presence of Jaime, Warlito, and Roche near the scene of the crime provided encouragement and a sense of security to Oscar, the group's preceptor. Their immediate flight and tarriance until their arrest also demonstrate their guilt and desire to evade prosecution.

5. The crime committed against Noemi Dulay should be denominated as attempted murder because none of her injuries was fatal. The fact that her attending physician made conflicting statements about the severity of her wounds further supports this designation.

6. The case falls under Art. 48 of The Revised Penal Code on complex crimes because the three murders and attempted murder were produced by a single act - the explosion caused by the hurling of a grenade into the bedroom of the Dulays. The penalty for the more serious crime, which in this case is reclusion perpetua to death, should be applied in its maximum period.

7. The agreed amount of P600,000.00 as civil damages should not be given force and effect because the defense counsel did not have a specific power of attorney from accused-appellants to compromise their civil liability. The settlement, therefore, violated existing law and jurisprudence.

8. The Court, by a majority vote, ruled that RA 7659 is constitutional and that the death penalty should be accordingly imposed. The assailed decision of the trial court finding the accused-appellants guilty of the crime of multiple murder with attempted murder and sentencing them to death was affirmed with some modifications in the amounts of indemnity and damages.

PRINCIPLES:

• Lie detector tests are not admissible as evidence as they have not been accepted by the scientific community as an accurate means of ascertaining truth or deception.

• The trial court's assessment of the credibility of witnesses is generally not disturbed on appeal unless there is an oversight, misunderstanding, or disregard of important facts.

• Inconsistent affidavits are not necessarily inconsistent with testimonies given in court. Testimonies given in court command greater respect.

• Alibi defense is futile when proximity to the scene of the crime can be established.

• In conspiracy cases, the presence of co-conspirators provides encouragement and a sense of security to the principal offender.

• Immediate flight and tarriance can be considered as evidence of guilt and the intent to evade prosecution.

• The crime of attempted murder requires that none of the wounds inflicted is severe enough to cause death.

• Complex crimes under Art. 48 of The Revised Penal Code involve multiple offenses arising from a single act.

• The attorney's power to compromise requires a clear mandate expressly given by the principal to the lawyer specifically authorizing the performance of an act.

• Without a specific power of attorney from the clients, defense counsel cannot bind or compromise their civil liability.

• The constitutionality of a law, particularly RA 7659 which prescribes the death penalty, can be questioned but the Court has the authority to determine its constitutionality.

• The determination of constitutionality of a law is based on the wisdom and authority vested in the legislative branch.

• The ruling on the constitutionality of a law is binding and must be followed unless reversed or modified by the Supreme Court.