Case Digest (G.R. No. 173282)
Facts:
The case involves Jose Ingal y Santos (petitioner) who was charged with the murder of Rolando N. Domingo, also known as Toto, which occurred on March 2, 1987, in Manila, Philippines. The Regional Trial Court (RTC) of Manila, Branch 2, convicted Ingal of murder, a decision that was later affirmed by the Court of Appeals on August 31, 2005. The prosecution's case was built on the testimonies of several witnesses, including Myrna Nalangan Domingo, the victim's mother, and Aida Bona, the owner of the carinderia (a small eatery) where the stabbing took place.
On the night of the incident, while Rolando Domingo was eating at the carinderia, Ingal approached him, pulled his hair, and stabbed him multiple times with a deadly weapon. Witnesses Aida Bona and Rosalinda Tan testified that they saw Ingal stab the victim. The victim was taken to Mary Johnston Hospital, where he succumbed to his injuries later that day. The prosecution presented various witnesses, including medic...
Case Digest (G.R. No. 173282)
Facts:
- Incident Overview: On 2 March 1987, Rolando Domingo, a 19-year-old student, was stabbed to death in a carinderia owned by Aida Bona in Tondo, Manila. The assailant was identified as Jose Ingal, who allegedly stabbed Domingo multiple times with a "tres cantos" (a bladed weapon).
- Prosecution Witnesses:
- Myrna Nalangan Domingo: The victim’s mother testified about her son’s death and the emotional and financial impact it caused.
- Aida Bona: The carinderia owner testified that she witnessed Ingal stab Domingo and identified him by a mole on his eyelid. She delayed giving a written statement until Ingal was arrested.
- Rosalinda Tan: A helper at the carinderia corroborated Bona’s testimony, stating she saw Ingal stab Domingo.
- Dr. Marcial G. Ceñido: Conducted the autopsy and confirmed the victim suffered four stab wounds, two of which were fatal.
- Police Officers: SPO2 Leon Salac and PFC Benjamin Boco testified about the investigation and arrest of Ingal.
- Defense Witnesses:
- Ricardo de Leon: Claimed that a person named Joseph, not Ingal, stabbed Domingo, and that Ricardo Lidot handed the weapon to Joseph.
- Remedios Ibajo: Testified that she saw Lidot and Joseph at the scene but did not see Ingal.
- Jose Ingal: Denied involvement, claiming he was at work delivering fish during the time of the incident.
- Trial Court Decision: The Regional Trial Court (RTC) convicted Ingal of murder, sentencing him to reclusion perpetua. The Court of Appeals affirmed the decision.
Issue:
- (Unlock)
Ruling:
- (Unlock)
Ratio:
- Credibility of Witnesses: The Court upheld the credibility of Aida Bona and Rosalinda Tan, noting that minor inconsistencies in their testimonies did not diminish their reliability. Their identification of Ingal as the assailant was clear and consistent. The delay in giving written statements was justified by their fear of reprisal.
- Conspiracy Not Proven: While the information alleged conspiracy, the prosecution failed to prove it. Only Ingal’s direct participation in the stabbing was established.
- Treachery Established: The attack was sudden and unexpected, rendering the victim unable to defend himself. This qualified the killing as murder under Article 248 of the Revised Penal Code.
- Defense of Alibi and Denial Rejected: Alibi is a weak defense, and Ingal failed to prove it was physically impossible for him to be at the crime scene. His denial was unsubstantiated and could not outweigh the positive identification by prosecution witnesses.
- Damages Awarded: The Court awarded civil indemnity, moral damages, temperate damages, and exemplary damages to the victim’s heirs, consistent with prevailing jurisprudence.