Case Digest (G.R. No. 172744)
Facts:
The case involves Marvin Angeles as the petitioner and the People of the Philippines as the respondent, with the decision rendered on September 29, 2008, by the Second Division of the Supreme Court. The events leading to the case occurred on July 18, 1996, at a videoke bar owned by Mr. Acleta in Sitio Ibabaw, National Road, Morong, Bataan. On that evening, Cesar Calma, Arnold ZuAiga, and Louie Marquez were drinking at the bar when Angeles, along with Garcia and two others, arrived, all of whom were intoxicated. A confrontation ensued when Prenil Bagang, a customer outside the bar, called for Garcia, leading to a physical altercation instigated by Angeles. During the fray, Angeles struck Calma with the handle of a gun and subsequently shot him in the back as he attempted to flee. Calma was seriously injured but survived due to timely medical intervention. The Regional Trial Court (RTC) of Balanga, Bataan, found Angeles guilty of frustrated homicide based on the testimonies of ...
Case Digest (G.R. No. 172744)
Facts:
Marvin Angeles (Angeles) was the petitioner in this case, facing charges for frustrated murder. The prosecution filed an information for frustrated murder against Angeles, who pleaded not guilty during the arraignment. The prosecution presented four witnesses: Cesar Calma (Calma), Arnold ZuAiga (ZuAiga), Louie Marquez (Marquez), and Dr. Luisito Celestino (Dr. Celestino), who attended Calma. The defense also presented four witnesses: Angeles himself, Prenil Bagang (Bagang), Danilo Alberto (Alberto), and Garcia Garcia (Garcia). The prosecution established the following key facts:
On the evening of July 18, 1996, Calma was drinking with ZuAiga and Marquez at a videoke bar in Sitio Ibabaw, Morong, Bataan. Angeles, Garcia, and two others arrived at the bar, all drunk. A scrimmage ensued, during which Angeles struck Calma on the right eye with the handle of a gun and shot him at the back. Calma and ZuAiga hid in a dry canal, escaping the shooting rampage of Angeles. Calma was brought to a health center and later to the provincial hospital, where he was confined for one week. Calma incurred medical expenses of P5,935.55 and lost income due to his injuries. Angeles denied the prosecution's account, claiming that envy motivated Calma to file the case against him.
Issue:
The primary issue was whether Marvin Angeles was guilty of frustrated homicide. The defense attempted to pin the crime on ZuAiga, but the court found this assertion not worthy of credence. Angeles sought reconsideration of the decision, but the RTC denied his motion. The case was appealed to the Court of Appeals, which affirmed the RTC's ruling. The present petition for review before the Supreme Court was based on the appellate court's affirmation of the RTC's decision.
Ruling:
The Court of Appeals affirmed the RTC's ruling, which found Angeles guilty of frustrated homicide. The appellate court sustained the RTC's assessment of the credibility of the prosecution's witnesses and gave them full faith and credence. The Supreme Court agreed with the Court of Appeals, finding no reason to deviate from the rule that the trial court's evaluation of witness testimonies is respected on appeal. The RTC correctly applied the Indeterminate Sentence Law for frustrated homicide, sentencing Angeles to an indeterminate penalty of two (2) years, four (4) months, and one (1) day of prision correccional as minimum to eight (8) years and one (1) day of prision mayor as maximum. The awards of P5,935.55 medical expenses incurred by Calma as actual damages and P30,000.00 as moral damages were also proper. The Supreme Court affirmed the decision of the Regional Trial Court.
Ratio:
- (Unlock)