Case Digest (G.R. No. 175980)
Facts:
People of the Philippines v. Adriano Cabrillas, G.R. No. 175980, February 15, 2012, First Division, Del Castillo, J., writing for the Court. Appellant Benny Cabtalan was tried for the murder of Jesus Cabujat; co-accused Adriano Cabrillas remained at large.On July 11, 1999, Jesus was allegedly attacked in Barangay Laygayon, Pinabacdao, Samar. The Information charged Benny and Adriano with conspiring to stab Jesus with long bolos, inflicting multiple fatal wounds. Benny was later arrested in Las Piñas on July 31, 2001; Adriano was not apprehended. Benny pleaded not guilty and trial proceeded in Regional Trial Court (RTC), Branch 33, Calbiga, Samar.
At trial the prosecution produced eyewitnesses: Wilfredo Pacayra, who testified he saw Benny and Adriano lurking in a dark part of the road, then hold Jesus while alternately stabbing him as Jesus urinated; 9‑year‑old Jonalyn Raypan, Jesus’s granddaughter, who corroborated the presence and positive identification of the assailants; and Elena Raypan, who heard Jesus call for help and heard him identify his attackers. Jesus was taken to hospital and pronounced dead from multiple stab wounds; his purported dying declaration was that Benny and Adriano stabbed him. Benny testified to an alibi: he claimed to have been elsewhere that night after a drinking spree and later left for Paranaque; his mother testified about Adriano confessing to an attack.
The RTC (Aug. 29, 2002) convicted Benny of murder, finding treachery, abuse of superior strength, and conspiracy, and sentenced him to death, with awards for civil, exemplary and moral damages. The case was forwarded for automatic review but, pursuant to People v. Mateo, referred to the Court of Appeals (CA). The CA (Aug. 29, 2006) affirmed the conviction but absorbed abuse of superior strength into treachery, reduced the penalty to r...(Subscriber-Only)
Issues:
- Was the evidence sufficient to convict Benny Cabtalan beyond reasonable doubt?
- Did treachery attend the killing so as to qualify it as murder?
- Was Benny’s alibi sufficiently proved to exonerate him?
- What is the proper penalty and damages, including parole eligibility, given the a...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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