People vs. Maliput

G.R. No. 116486 (January 29, 1996)

Maliput and Daprosa convicted of double murder; court upheld confessions and clarified treachery, premeditation.

Facts:

On the night of April 7, 1991, Chua Chun and Ho Tin, a couple who owned Popongas Grocery in San Fernando, Pampanga, were brutally murdered. The police discovered Ho Tin's body near the grocery's side door, with her hands bound and her head covered with a rice sack. Chua Chun was found in the bathroom, his throat slashed and his hands also bound. The crime scene revealed several weapons, including a screwdriver fashioned into an ice pick and bloodstained glass shards.

The investigation led to the identification of two suspects, Rodrigo Maliput y Reyes and Undo Daprosa y Watig (alias Alexander Jumawan), both employees of the grocery. They were apprehended after being spotted hiding near a marble store. Following their arrest, both suspects allegedly confessed to their involvement in the murders.

On June 3, 1991, the provincial prosecutor filed an information charging Maliput and Daprosa with double murder, alleging that they conspired to kill the victims with treachery and evident premeditation.

During the trial, Tony Choi, the son of the victims, testified that he saw three individuals, including Maliput and Daprosa, fleeing the grocery just before he discovered his parents' bodies. The defense presented alibi and denial, claiming they were not present during the crime and that they had left the grocery out of fear for their lives after being threatened by a former employee, Jun-Jun Reyes.

Legal Issues:

  1. Whether the prosecution established the guilt of the accused beyond a reasonable doubt.
  2. Whether the defense's alibi and denial were credible in light of the evidence presented.

Arguments:

Prosecution:

  • The prosecution argued that the positive identification of Maliput and Daprosa by Tony Choi, along with circumstantial evidence, established their guilt.
  • The prosecution emphasized the brutality of the crime and the motive of the accused, who were employees of the victims.

Defense:

  • The defense contended that there was no direct evidence linking the accused to the crime, arguing that the prosecution's case relied solely on circumstantial evidence.
  • They claimed that the accused had no motive to kill their employers, who had treated them well, and that their alibi was credible.

Court's Decision and Legal Reasoning:

The court affirmed the trial court's decision, finding Maliput and Daprosa guilty beyond a reasonable doubt of double murder. The court reasoned that the positive identification by Tony Choi was credible and corroborated by the circumstances surrounding the crime. The court noted that the defense's alibi was weak, as it lacked corroboration and was contradicted by the evidence of flight, which indicated guilt.

The court also highlighted that while there was no direct evidence of the accused committing the murders, the circumstantial evidence presented formed an unbroken chain leading to the conclusion of their guilt. The court found that the brutality of the crime, including the use of superior strength against unarmed victims, supported the finding of treachery and evident premeditation.

Significant Legal Principles Established:

  • The case underscores the principle that positive identification by a credible witness can suffice to establish guilt, even in the absence of direct evidence.
  • It also illustrates that flight from the scene of a crime can be indicative of guilt and can undermine claims of innocence.
  • The ruling reinforces the notion that circumstantial evidence, when sufficiently strong and consistent, can lead to a conviction.