People of the Philippines vs.

Charlie Fieldad, Ryan Cornista, Edgar Pimentel

G.R. No. 196005
1 October 2014
Facts:
The appellants Fieldad, Cornista, and Pimentel stand accused of the murder of two BJMP Jail
guards within the detention compound of their incarceration; as well as the theft of a car to
facilitate their escape from prison. The accused proffered the alibi that that they were
elsewhere from the nipa hut where the guards were killed; that they did not conspire with
treachery; and that they were only inspired with fear to steal and drive the car--but both trial
court and court of appeals were unconvinced. Come now, the accused, to the Supreme Court-their last recourse.
Appeal dismissed.
Issues and Answer:
WON there was treachery.
Yes, there was.
While the victims may have been issued and armed with government firearms such is not a
decisive arbiter of the presence and absence of treachery. The Supreme Court elucidates thus:
"There is treachery when the offender commits any of the crimes against the person,
employing means, method, or forms in the execution, without risk to himself arising from the
defense which the offended party might take."
In the present case, it is clear that the victims were overwhelmed and their firearms taken from
them and used against them.
WON Fielded was identified.
Yes, Fieldad was categorically identified by the witness Badua.
"It is a settled rule that the evaluation of the credibility of the witnesses and their testimonies
is a matter best undertaken by the trial court...Positive identification of the accused is entitled
to greater weight than the bare denial and explanation by the accused."
The SC further explains, "Fieldad's self-serving defense of denial and alibi must fail. Alibi is the
weakest of all defenses, as it is easy to contrive and difficult to disprove. True, the conviction of
an accused must rest not on the weakness of the defense but on the strength of the
prosecution evidence. Hence, when the prosecution evidence has firmly established the guilt of
accused beyond reasonable doubt, conviction is in order."
WON prosecution's evidence is sufficient.
Yes, it was.
The Positive identification of Fieldad by Badua was corroborated by circumstantial evidence.
also, Fieldad failed to controvert the paraffin evidence used to indicate gunshot residue. We
note that Fieldad's counsel manifested during trial that the paraffin casting was performed
without the assistance of counsel, contrary to the right of the accused. This is untenable
since, "the taking of paraffin casts does not violate the right of the accused against self
incrimination." Said right, "extends only to testimonial compulsion and not when the body of
the accused is proposed to be examined."
WON there was conspiracy.
Yes, there was.

A conspiracy exists when two or more persons come to an agreement concerning the
commission of a felony and decide to commit it. Conspiracy can be inferred from and
established by the acts of the accused themselves when said acts point to a joint purpose and
design, concerted action and community interest. Contrary to his contentions, the acts of
Fieldad before, during and after the attacks on JOs Bacolor, Jr. and Gamboa disclose his
agreement with the joint purpose and design in the commission of the felonies. The positive
testimony of Badua is corroborated by a web of circumstantial evidence that points to no other
conclusion than that Fieldad was complicit in the conspiracy to murder the jail guards.
WON there was uncontrollable fear.
No, it is clear and established that for uncontrollable fear to apply the person must be so
reduced by duress, intimidation, or the threat of harm that he becomes a mere instrument
against his will with no hope of escape or self-defense.
In this case, the evidence provides that appellants had three opportunities for escape and only
one of their alleged oppressors was armed. To be believed, testimony must not only proceed
from the mouth of a credible witness; it must be credible in itself such as the common
experience and observation of mankind can approve as probable under the circumstances.
Here, it is not.