## Title:
People of the Philippines vs. Alberto Santos and Isabelo Cruz, G.R. No. L-927
## Facts:
On February 25, 1946, Raymundo Feliciano was forcibly taken from his house in Cordon, Isabela, by Alberto Santos and Isabelo Cruz, along with other accomplices. Earlier, both Cruz and Santos had been involved in various interactions with Feliciano and his family members. On the evening of the abduction, Santos entered Feliciano’s house, threatened the occupants with a revolver, and dragged Feliciano downstairs with Cruz’s help. They were joined by several men outside. Feliciano was blindfolded and later found dead with gunshot wounds in a nearby grove. Key witness testimonies pinned Santos and Cruz as the perpetrators. Santos’ defense was an unconvincing alibi, while Cruz fabricated an implausible story of coercion by other companions.
## Issues:
1. Whether or not the appellants were guilty of the abduction and subsequent murder of Raymundo Feliciano.
2. Whether the trial court erred in sentencing the appellants to reclusion perpetua.
3. Whether the indemnity awarded by the trial court to the heirs of the deceased should be increased.
## Court’s Decision:
1. **Guilt of the Appellants:**
– The Supreme Court found that the facts and testimonies presented by the prosecution were credible and consistent. Despite the appellants’ defenses, Santos and Cruz were identified as having participated directly in the abduction and subsequent killing of Feliciano. The defense’s alibis and fabricated stories failed to create reasonable doubt.
– **Ruling:** Santos and Cruz were guilty beyond a reasonable doubt of murder and kidnapping.
2. **Sentencing to Reclusion Perpetua:**
– The Court upheld the trial court’s imposition of reclusion perpetua, recognizing the severity of the crime committed by the appellants.
– **Ruling:** The sentence of reclusion perpetua was affirmed.
3. **Indemnity to Heirs:**
– The prosecution recommended increasing the indemnity from P2,000.00 to P6,000.00. The Court accepted this recommendation, considering it consistent with the prevailing rule in comparable cases.
– **Ruling:** The compensation amount was increased from P2,000.00 to P6,000.00.
## Doctrine:
The case solidifies the doctrine that uncorroborated and implausible defenses will not stand against direct and consistent testimony backed by credible evidence. It also underscores the principle of increasing indemnity for heirs based on the rule established in People vs. Amansec.
## Class Notes:
– **Crime Elements:** Abduction, kidnapping, murder, use of firearm in commission.
– **Key Principles:** Credibility of witnesses, insufficiency of alibi and fabricated stories, reclusion perpetua for heinous crimes.
– **Statutes:** Revised Penal Code provisions on kidnapping with murder.
– **Application:** Clear liability based on consistent witness testimony despite weak defenses presented.
## Historical Background:
The case is set in the immediate post-World War II era in the Philippines, a time marked by radical political changes and an uptick in heinous crimes. It reflects the challenges faced by the nascent Philippine government in restoring order and delivering justice efficiently after the turmoil of the Japanese occupation and the ensuing liberation.
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