People vs. Quijada

G.R. No. 115008-09 (July 24, 1996)

Facts:

The case involves Daniel Quijada, who was charged with murder and illegal possession of a firearm following an incident on December 30, 1992, in Dauis, Bohol. The prosecution alleged that Quijada shot Diosdado Iroy, the victim, in the back of the head using a .38 caliber revolver during a benefit dance. The shooting occurred after a prior altercation between Quijada and Iroy, where Quijada had been pestering Iroy's sister. Witnesses, including Rosita Iroy (the victim's sister), testified that they saw Quijada approach and shoot Iroy without provocation. The victim was rushed to the hospital but succumbed to his injuries.

The police were informed of the incident shortly after it occurred, and Quijada was later identified by witnesses as the shooter. The firearm used in the crime was found to be unlicensed, and Quijada did not possess the necessary permits to carry it. The trial court consolidated the two charges and conducted joint hearings, where both the prosecution and defense presented their evidence.

Quijada's defense was primarily based on alibi, claiming he was in Tagbilaran City at the time of the shooting. However, the trial court found the prosecution's evidence more credible, leading to Quijada's conviction for both murder and illegal possession of a firearm.

Legal Issues:

1. Whether the trial court erred in convicting Quijada based on the testimonies of the prosecution witnesses.
2. Whether the defense of alibi presented by Quijada was sufficient to exonerate him from the charges.
3. The applicability of the doctrine of double jeopardy concerning the separate charges of murder and illegal possession of a firearm.

Arguments:

For the Prosecution:

• The prosecution argued that Quijada acted with treachery and evident premeditation, as he shot Iroy from behind without giving him a chance to defend himself.
• Witnesses, particularly Rosita Iroy, provided consistent and credible testimonies identifying Quijada as the shooter.
• The prosecution maintained that the evidence clearly established Quijada's guilt beyond a reasonable doubt.

For the Defense:

• Quijada's defense contended that the testimonies of the prosecution witnesses were unreliable and that Rosita Iroy had a motive to falsely accuse him due to their prior altercation.
• The defense emphasized Quijada's alibi, asserting that he was in Tagbilaran City at the time of the shooting, which should have created reasonable doubt regarding his presence at the crime scene.
• The defense also argued that the prosecution failed to present all potential witnesses who could corroborate Quijada's alibi.

Court's Decision and Legal Reasoning:

The Supreme Court upheld the trial court's decision, affirming Quijada's conviction for both murder and illegal possession of a firearm. The Court found that:

• The testimonies of the prosecution witnesses, particularly Rosita Iroy, were credible and consistent. The Court noted that the trial court had the advantage of observing the demeanor of the witnesses, which contributed to its assessment of their credibility.
• The defense of alibi was insufficient to exonerate Quijada, as it did not establish that it was physically impossible for him to be at the crime scene at the time of the shooting. The distance between Tagbilaran City and the crime scene was not far enough to support the alibi.
• The Court reiterated the principle that the use of an unlicensed firearm in the commission of a crime constitutes two separate offenses: murder under the Revised Penal Code and illegal possession of a firearm under P.D. No. 1866. The Court emphasized that these offenses are distinct and do not violate the constitutional protection against double jeopardy.

Significant Legal Principles Established:

1. The credibility of witnesses is paramount in determining the outcome of criminal cases, and the trial court's assessment of witness demeanor is given great weight.
2. The defense of alibi must not only prove that the accused was elsewhere but also demonstrate that it was physically impossible for them to be at the crime scene.
3. The use of an unlicensed firearm in committing a homicide or murder results in separate charges for both offenses, and the principle of double jeopardy does not apply in such cases.