People of the Philippines vs. Raymundo Araja and Roding Araja
### Facts:
On November 29, 1962, Apolonio Aquino, accompanied by his friend Epifanio Umali, traveled to Barrio San Gabriel, Talisay, Batangas to serenade Gregoria Bathan, a girl Aquino was courting. Bathan’s parents disapproved of Aquino and moved her to San Gabriel to keep them apart. After the serenade, while Aquino and his group were standing in front of Leodegario Bait’s store, someone shouted “patay kayo ngayon” (you’re dead now). Aquino shone his flashlight in the direction of the voices, revealing Raymundo and Roding Araja holding firearms. Both fired at Aquino, who fell and cried “aray” before succumbing to his injuries. Eyewitness Epifanio Umali testified to the events, identifying both accused.
Philippine Constabulary (PC) soldier Victoriano Antazo arrived at the scene and took Aquino’s dying declaration, where Aquino identified his attackers as “the sons of Purok from San Gabriel, Talisay, Batangas.” Aquino reiterated to his father, Catalino Aquino, that Raymundo and Roding Araja shot him due to a dispute over Gregoria Bathan.
PC Sgt. Michael Anduque found five empty shells at the crime scene. NBI medico-legal officer Dr. Ceferino Cunanan confirmed the existence of two gunshot wounds on Aquino’s body, concluding he could have lived for an hour before dying. Both accused were arrested, released, and then rearrested a month later.
### Issues:
1. Whether the prosecution established beyond reasonable doubt the identity of the appellants as Aquino’s assailants.
2. Whether the dying declaration and eyewitness testimony were admissible and sufficient to convict.
3. Whether the alibi presented by the defense was credible.
4. Whether aggravating circumstances of treachery, abuse of superior strength, use of unlicensed firearms, and nocturnity could be applied.
### Court’s Decision:
**Identity of the Assailants:**
The Supreme Court ruled that the prosecution had sufficiently established the identity of Raymundo and Roding Araja. Despite minor inconsistencies, the dying declaration taken by PC soldier Antazo was deemed credible. Aquino was under the imminent belief of death while making the statement, which was consistent with legal requirements for a dying declaration.
**Admissibility of Testimony:**
Eyewitness testimony from Umali corroborated the dying declaration. The court noted that Umali had no motive to falsely testify against the appellants. The proximity and visibility allowed Umali to positively identify them. The court found the testimony credible.
**Defense of Alibi:**
The court found the alibi unconvincing because the crime scene was within close range (30 meters) from Raymundo Araja’s house and approximately 1/2 kilometer from Roding Araja’s house, making it possible for them to be present at the crime scene.
**Aggravating Circumstances:**
The court confirmed the presence of treachery as the attack was sudden and unexpected, rendering Aquino incapable of defending himself. However, evident premeditation was not proven satisfactorily. The court deemed that abuse of superior strength and nocturnity were absorbed in treachery.
The verdict of guilt for murder qualified by treachery was affirmed, with the penalty of reclusion perpetua. The court increased the civil indemnity from P6,000 to P12,000.
### Doctrine:
1. **Dying Declaration and Res Gestae:** The dying declaration is admissible when given under the impending threat of death. It is also admissible as part of res gestae if made spontaneously and shortly after the incident.
2. **Positive Identification:** Positive identification from credible eyewitnesses holds significant weight against the defense of alibi.
3. **Absorption of Aggravating Circumstances:** In cases where treachery is established, other aggravating circumstances such as abuse of superior strength and nocturnity are often absorbed.
### Class Notes:
– **Key Elements of Murder (Article 248, Revised Penal Code):**
– Unlawful killing
– With treachery, premeditation, or other qualifying circumstances
– Positive identification of the accused as perpetrators
– **Dying Declaration (Rule 130, Section 37, Rules of Court):**
– Declaration about the cause and circumstances of death
– Made under consciousness of impending death
– **Alibi (Rule 134, Section 3, Revised Rules of Court):**
– The accused must show physical impossibility to be at the scene
– **Treachery (Article 14, Revised Penal Code):**
– Suppresses any means of defense or retaliation by the victim
### Historical Background:
This case is set within the context of personal vendettas often associated with familial and romantic conflicts during the early 1960s in rural Philippine communities. It examines themes of honor, familial loyalty, and the gravity of criminal acts within close-knit communities, reflecting the socio-cultural milieu of the time.
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