This case explores the delicate balance between religious affiliation and individual accountability in the context of a brutal crime. The Supreme Court affirmed the conviction of Fernando “Ando” Costales for murder and attempted murder, underscoring that membership in a religious group does not shield individuals from criminal liability. Furthermore, it emphasizes that conspiracy can be inferred from the coordinated actions of perpetrators, demonstrating a shared intent to commit unlawful acts.

When Faith Turns Fatal: Unraveling the Motives Behind a Brotherhood’s Betrayal

The backdrop of this case is the tragic murder of Miguel Marcelo and the attempted murder of his wife, Crispina, allegedly committed by fellow members of the “Baro a Cristiano” religious group. The prosecution presented compelling witness testimonies from Crispina and her daughters, Jessie and Erlinda, who recounted the harrowing events of the night. They identified Fernando “Ando” Costales and Fernando Ramirez as the assailants, with Costales shooting Miguel and Ramirez spraying a chemical irritant before shooting Crispina. The motive, as suggested by the prosecution, stemmed from the Marcelo family’s decision to leave the religious sect due to threats and alleged abuses by Ramirez.

Costales, in his defense, presented an alibi, claiming he was elsewhere tending to his farmland and attending religious services. He offered corroborating testimonies from his wife and neighbors. However, the trial court dismissed his alibi as weak and inconsistent, giving greater weight to the prosecution’s witnesses. The court noted that the witnesses had a clear view of the assailants, who were well-known to them, and that the small size of their home allowed them to observe the events clearly. It also highlighted inconsistencies in the testimonies of the defense witnesses.

A central legal issue was whether Costales’s guilt was proven beyond a reasonable doubt. The Supreme Court scrutinized the evidence, paying particular attention to the credibility of the witnesses. It upheld the trial court’s assessment that the prosecution witnesses were more credible, finding no evidence of ill motive that would cause them to falsely accuse Costales. “Clearly, the straightforward and consistent narration of facts, as the trial court observed, by the three (3) prosecution witnesses, especially Crispina Marcelo, a victim herself, immensely fortifies the conclusion that accused-appellant is guilty as charged.”

Moreover, the Court examined the application of Presidential Decree No. 1866, which penalizes illegal possession of firearms. The court clarified that under Republic Act No. 8294, the use of an unlicensed firearm is considered a special aggravating circumstance in murder and homicide, rather than a separate offense. While illegal possession was proven, the information lacked specific details, which barred the court from appreciating it. As stated:

As it should be, possession and use of firearm without license should aggravate the crimes of murder and frustrated murder as herein charged but, fortunately for accused-appellant, Secs. 8 and 9 of the Revised Rules on Criminal Procedure, which took effect 1 December 2000, now require the qualifying as well as aggravating circumstances to be expressly and specifically alleged in the complaint or information, otherwise the same will not be considered by the court even if proved during the trial.

Furthermore, the court tackled the aggravating circumstances of evident premeditation and nighttime, ultimately concluding that only treachery was appropriately appreciated. It found that the attack’s sudden and unexpected nature denied the victims any chance of defense, thus satisfying the elements of treachery. Nighttime, however, was deemed absorbed by treachery. Importantly, the Court affirmed the finding of conspiracy, inferring a common design from the synchronized actions of Costales and Ramirez. They acted in concert and unity with their unlawful objective. The determination of the absence of voluntary surrender also plays a key role because as “found by the trial court, his alleged surrender was made too late, and in a place too distant from the crime site as well as his place of residence.”

Finally, the Supreme Court corrected the trial court’s award of damages, emphasizing that such awards must align with the law and jurisprudence, rather than being dictated by the parties’ agreement. Therefore, the Court awarded civil indemnity and moral damages to the heirs of the victim, Miguel Marcelo.

FAQs

What was the key issue in this case?	The key issue was whether the accused, Fernando Costales, was guilty beyond reasonable doubt of the murder of Miguel Marcelo and the attempted murder of Crispina Marcelo, despite his alibi and claims of biased witnesses.
How did the Court assess the credibility of the witnesses?	The Court relied on the trial court’s assessment, giving weight to the prosecution witnesses’ consistent testimonies and finding no evidence of ill motive that would cause them to falsely accuse the accused.
What was the significance of Republic Act No. 8294 in this case?	R.A. 8294 reclassified the use of an unlicensed firearm from a separate offense to a special aggravating circumstance in murder and homicide. However, it could not be appreciated in this case because it was not specifically alleged in the information.
What is the legal definition of treachery, as applied in this case?	Treachery exists when the offender commits any of the crimes against the person, employing means, methods, or forms in the execution thereof which tend directly and specially to ensure its execution, without risk to himself arising from the defense which the offended party might make.
How did the Court determine the presence of conspiracy?	The Court inferred conspiracy from the coordinated actions of the accused and his accomplice, demonstrating a shared intent and agreement to commit the unlawful acts.
Why was voluntary surrender not considered a mitigating circumstance?	The accused’s surrender was deemed too late and too distant from the crime site and his residence, failing to meet the requirements for voluntary surrender as a mitigating circumstance.
How did the Court modify the trial court’s decision regarding damages?	The Court corrected the trial court’s award of damages, emphasizing that such awards must align with the law and jurisprudence, rather than being dictated by the parties’ agreement. The Court then awarded ₱50,000 as civil indemnity and another ₱50,000 as moral damages.
What was the final verdict in this case?	The Supreme Court affirmed the conviction of Fernando “Ando” Costales for murder and attempted murder, modifying the sentence to reclusion perpetua for murder, and imposing an indeterminate prison term for attempted murder.

This case underscores the importance of individual accountability, regardless of religious affiliation, and reinforces the principle that conspiracy can be inferred from coordinated actions. It provides clarity on the application of Republic Act No. 8294 regarding the use of unlicensed firearms and reiterates the standards for appreciating aggravating and mitigating circumstances. This ruling highlights the court’s dedication to ensuring justice and adherence to legal procedures.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: People v. Costales, G.R. Nos. 141154-56, January 15, 2002