Title
Anilao vs. People
Case
G.R. No. 149681
Decision Date
Oct 15, 2007
A cyclist, Ronald Apud, was stabbed by Rammel Monares Anilao after a confrontation, leading to a conviction for frustrated homicide. The Supreme Court upheld the ruling, citing credible witness testimonies and rejecting the defense's claims.
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Case Digest (G.R. No. 149681)

Facts:

Incident Details

  • On January 15, 1994, at around 8:45 p.m., private complainant Ronald Apud was riding his bicycle in Purok Pagkaisa, Barangay Saliao, Esperanza, Sultan Kudarat.
  • He encountered petitioner Rammel Monares Anilao alias Jojo and a companion. Petitioner allegedly said, "Ara si Nonoy Apud, birahan ta" (Here comes Nonoy Apud, we will hit him). The companion replied that it was not Nonoy Apud.
  • Apud continued biking but later decided to return to warn his brother, Efren Apud alias Nonoy, about the threat. On his way back, he passed by petitioner and his companion again but did not find his brother.

The Attack

  • Apud decided to go home to his brother Antonio Apud's house. While biking near the Notre Dame Cooperative store, petitioner allegedly grabbed the steering wheel of Apud's bicycle and pulled it to the right side.
  • Petitioner then stabbed Apud on the upper right side of his waist towards the back, causing him to fall. Petitioner fled the scene.
  • Apud was brought to a clinic by his brother Efren and later to another clinic for surgery due to the severity of the wound.

Identification of the Accused

  • Nine days after the incident, on January 24, 1994, Apud saw petitioner pass by on a tricycle near his uncle's house. He identified petitioner as the person who stabbed him.

Medical Evidence

  • Dr. Jesus Galapate testified that Apud sustained a serious stab wound that could have caused his death if not for timely medical intervention.

Defense Version

  • Petitioner claimed that Apud bumped him with his bicycle, hitting his left leg. He held the bicycle's steering wheel, but Apud lifted it and thrust it at him, hitting his chest.
  • Petitioner boxed Apud, causing him to fall. While they were struggling, a certain "Joe" approached and stabbed Apud, then fled.

Issue:

  1. Whether the Court of Appeals erred in failing to apply the equipoise doctrine, which requires acquittal when evidence is evenly balanced.
  2. Whether the Court of Appeals violated petitioner's right to due process by not considering his private counsel's brief.
  3. Whether the Court of Appeals failed to appreciate facts that could lead to petitioner's acquittal.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)


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