Title
Supreme Court
Oliveros, Jr. vs. People
Case
G.R. No. 242552
Decision Date
Mar 3, 2021
Petitioners charged with Frustrated Murder for attacking Glenn Apostol; claimed self-defense. SC ruled Attempted Murder, citing insufficient proof of fatal injuries, imposed reduced penalty and damages.

Case Digest (G.R. No. 242552)
Expanded Legal Reasoning Model

Facts:

  • Procedural Background
    • Petitioners Benjamin M. Oliveros, Jr., Oliver M. Oliveros and Maximo Z. Sotto were charged with frustrated murder before the RTC of Lingayen, Pangasinan (Crim. Case No. L-9894).
    • The RTC convicted them of frustrated murder (Nov. 16, 2015). On appeal, the CA affirmed with modified damages (Jan. 31, 2018). Petitioners filed a Rule 45 petition before the SC.
  • Incident and Trial
    • On October 30, 2013 at Poblacion public market, Binmaley, Pangasinan, petitioners, armed with bolos, conspired to attack Glenn F. Apostol (private complainant) and his father Virgilio. They punched, hacked (9 cm wound on left zygomatic area; 5 cm on right shoulder; 3 cm frontal laceration; cheekbone fracture) and mauled the victims.
    • The victims were rushed to hospital; prompt medical intervention prevented death.
    • Prosecution witnesses: Glenn Apostol, Virgilio Apostol, eyewitness Irma delos Santos, and Dr. Melquiades Manaois.
    • Defense witnesses: Benjamin, Oliver, Maximo and their sister Mimielyn Sotto, who claimed self-defense/defense of a relative and denied concerted intent.

Issues:

  • Did the CA err in upholding the conviction for frustrated murder?
  • Were the elements of frustrated murder—intent to kill, abuse of superior strength, and fatal nature of wounds—sufficiently proven?
  • Were claimed justifying (self-defense/defense of a relative/stranger) or mitigating circumstances (passion/obfuscation) established?

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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