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MARIA TIFFANY QUESADA LAGARNIA

Criminal Law 1-Case Digest

People v. Gonzales
183 SCRA 309 (1990)

Facts: Appeal of Custodio Gonzales, Sr. that the CA erred in convicting him of murder qualified
with treachery and evident premeditation from a previous case on the sole basis of Huntoria’s
(eye witness) account.

Previous case: That appellant with his 3 robust sons along with brother and sister Fausta and
Rogelio conspired to kill Augusto and Fausta’s landlord, Peñacerrada. The victim sustained 16
stab, puncture, and lacerated wounds, 5 of which were fatal. The lone eyewitness was Huntoria
who claimed that he saw all 6 accused ganging up on the victim, but he failed to state who
actually did the stabbing or hacking.
All the accused petitioned for parole except for appellant

Issues: WON the appellant had committed the felony of murder with treachery and evident
premeditation.

Held: No. The Court held that the prosecution was unable to prove the appellant’s guilt beyond
reasonable doubt because: (a) Huntoria was a poor eyewitness (took 8 months to come
forward and wanted to get in the good graces of his landlord’s family) and was unable to supply
any information as to what the appellant actually did (the act) in his alleged participation in the
murder; (b) it was illogical that the appellant’s 3 robust sons together with Augusto and Fausta
would bring their aging 65-year old father to the victim’s house just to participate in the killing
considering the appellant lived a good kilometer away from the scene of the crime; (c) the prior
investigations were sloppy and provided no decent evidence to support the appellant’s
participation in the murder.