People v. Manlusoc

G.R. No. 116600 (July 3, 1996)

Four police officers convicted of Isagani Mazon's murder, highlighting police accountability issues.

Facts:

On January 8, 1991, at approximately 9:30 PM in Calapan, Oriental Mindoro, four members of the Philippine National Police (PNP)—M/Sgt. Reynaldo Landicho, Pat. Johnny Bunyi, C1C Eric Manlusoc, and C2C Leovino Canuel—shot and killed Isagani Mazon, inflicting twenty-one gunshot wounds, many of which were to his back. The accused were charged with murder, but instead of being detained in a provincial jail, they were allowed to remain in the custody of their superiors at the PNP Stockade. They later escaped, allegedly with the complicity or negligence of their custodians. Only Eric Manlusoc was later apprehended.

The Regional Trial Court (RTC) in Calapan, Oriental Mindoro, issued a warrant for the arrest of the accused on October 17, 1991. The accused surrendered to the PNP office on October 24, 1991, and subsequently filed a petition for bail, which was denied. They were arraigned on November 5, 1991, and pleaded not guilty. Throughout the proceedings, there were multiple instances of the accused being seen outside the PNP Stockade without proper authorization, leading to concerns about their escape and the integrity of the judicial process.

The trial court eventually denied their petition for bail, citing strong evidence of guilt, and ordered their transfer to the Calapan Jail Center. Despite this, the accused continued to evade custody, leading to further legal complications and a trial in absentia after they failed to appear for scheduled hearings.

Legal Issues:

  1. Whether the trial court had jurisdiction over the case against the accused, given their status as public officers.
  2. Whether the evidence presented was sufficient to establish the elements of murder, including the presence of treachery and conspiracy.
  3. The implications of the accused's escape from custody on their right to present a defense.
  4. The appropriateness of the trial court's actions regarding the accused's repeated unauthorized absences from custody.

Arguments:

  • Prosecution's Argument: The prosecution argued that the accused conspired to kill Mazon, as evidenced by eyewitness testimonies and the nature of the attack, which was sudden and treacherous. They contended that the accused's escape from custody indicated guilt and that the trial court had sufficient grounds to convict them based on the evidence presented.

  • Defense's Argument: The defense contended that the trial court lacked jurisdiction over the case, asserting that crimes committed by public officers should fall under the jurisdiction of the Sandiganbayan. They also argued that the prosecution failed to prove the essential elements of murder, including the absence of evidence linking the appellant's actions directly to the victim's death. The defense further claimed that the testimonies of the prosecution witnesses were inconsistent and lacked credibility.

Court's Decision and Legal Reasoning:

The court affirmed the trial court's decision, finding the accused guilty of murder. It held that the trial court had jurisdiction over the case, as the law provided for the prosecution of PNP members in regular courts. The court found that the prosecution had established the elements of murder, including the qualifying circumstance of treachery, as the attack was sudden and left the victim with no opportunity to defend himself.

The court also ruled that the escape of the accused from custody was indicative of guilt and that their failure to present evidence in their defense was a waiver of that right. The court noted that the trial court's lapses in handling the case, including allowing the accused to leave custody without proper authorization, did not undermine the validity of the conviction.

Significant Legal Principles Established:

  1. Jurisdiction Over Public Officers: The case clarified that crimes committed by members of the PNP can be prosecuted in regular courts, despite their status as public officers.
  2. Treachery as a Qualifying Circumstance: The court reiterated that treachery can be established even if the victim had some awareness of danger, as long as the attack was sudden and left the victim unable to defend himself.
  3. Implications of Escape from Custody: The court emphasized that an accused's escape from custody can be interpreted as an admission of guilt and can affect their right to present a defense.