Case Digest (G.R. No. 140386)
Facts:
The case at hand is titled People of the Philippines vs. Benny Acosta and Renny Boy Acosta, which was decided by the Second Division of the Supreme Court on November 29, 2001 (G.R. No. 140386). The incident occurred around midnight on March 14, 1993, at Sitio Tuway, Barangay P. Zamora, Guihulngan, Negros Oriental. The accused, Benny Acosta and his son Renny Boy Acosta, were charged with murder following the stabbing of Norton Baguio, who succumbed to his injuries soon after the attack.On November 3, 1993, both accused pleaded not guilty during their arraignment. The prosecution presented six witnesses, including the police and medical experts, who testified that Norton Baguio had attended a dance celebration with friends when he was attacked from behind while urinating. Benny Acosta initiated the assault by stabbing him, after which Renny Boy joined in the attack. The victim, despite his grave injuries, managed to identify Benny Acosta as one of his assailants before dying fr
Case Digest (G.R. No. 140386)
Facts:
- Commission of the Crime
- On or about past midnight, March 14, 1993, in Sitio Tuway, Barangay P. Zamora, Guihulngan, Negros Oriental, the accused, Benny Acosta, together with his son, Renny Boy Acosta, was charged with the murder of Norton Baguio.
- The prosecution alleged that the accused, acting in concert, willfully, unlawfully, and feloniously attacked Norton Baguio with treachery and abuse of superior strength, specifically stabbing him from behind while the victim was vulnerable as he was urinating.
- The stabbing caused fatal wounds that led to internal hemorrhage, ultimately resulting in the death of the victim.
- Testimonies and Evidence Presented by the Prosecution
- Prosecution Witnesses
- Six prosecution witnesses testified, including Dr. Fe L. Mercado (the medical examiner), SPO2 Cecilio Nilles, Hansel CaAete, Joy Boganutan, Leonilo Baguio, and Adelia Patricio.
- Witness testimonies established the victim’s presence at a dance held at Sitio Tuway on the evening of March 13, 1993, where the fatal incident ensued on the following midnight.
- Description of the Incident
- While accompanying friends after the dance, Norton Baguio stopped to urinate behind a store; it was at this juncture that Benny Acosta suddenly attacked and stabbed him from behind.
- As the victim fell, Renny Boy Acosta also engaged by stabbing him, although the victim managed, with the help of his companions, to identify Benny Acosta as one of the assailants.
- Medical and Forensic Findings
- The postmortem examination revealed two stab wounds located on the victim’s left back: one at the upper back (near the scapular region) and another in the left lumbar area.
- Dr. Mercado testified that a sharp, pointed instrument—possibly a hunting knife—could have caused such wounds and noted the difficulty in determining if a single weapon was used for both wounds.
- Additional Evidence
- SPO2 Cecilio Nilles testified regarding the chain of custody of a long-bladed knife (with scabbard) that later showed traces of blood, linking it to the incident.
- Adelia Patricio, the victim’s aunt, testified on the expenses incurred due to the victim’s death, which later formed the basis for awarding civil indemnity.
- Defense’s Presentation and Claims
- Accused Benny Acosta’s Alibi
- Benny Acosta testified that from the afternoon of March 13, 1993 until around 1:00 a.m. on March 14, 1993, he was out sea fishing, later selling his catch at the residence of Romulo Perez, and watching a betamax film.
- He claimed ignorance of the incident until he was awakened by police on the morning of March 14, 1993.
- Cross-examination revealed that his residence was near the seashore and only about a 10-minute walk from the dance hall where the crime allegedly occurred.
- Defense of Self-Defense for Renny Boy Acosta
- The defense argued that Renny Boy Acosta acted in self-defense when he stabbed the victim, asserting that the victim was initially aggressive.
- However, testimony revealed that Norton Baguio had already fallen and ceased his assault prior to the subsequent stab, thereby undermining the self-defense claim.
- Eyewitness Testimonies in Support of the Prosecution
- Witnesses Hansel CaAete and Joy Boganutan, among others, provided accounts that placed both accused at the crime scene and described the fatal stabbings, thereby diminishing the credibility of the alibi and self-defense claims.
- Decision of the Trial Court
- On August 19, 1999, the Regional Trial Court, Branch 44, Dumaguete City, rendered its decision:
- Both Benny Acosta and Renny Boy Acosta were found guilty beyond reasonable doubt of murder.
- Benny Acosta was sentenced to suffer reclusion perpetua and ordered to pay civil indemnity of PHP 50,000.00 for the death of Norton Baguio.
- Renny Boy Acosta was sentenced to an indeterminate prison term (six years minimum to twelve years, five months, and ten days maximum), with the mitigating circumstance of minority duly noted for him.
- Only Benny Acosta appealed the judgment, contesting the weight given to eyewitness testimonies, the sufficiency of his alibi, and asserting that the trial court should have recognized the self-defense plea for his son.
- Contentions Raised on Appeal by Accused Benny Acosta
- Argued that the trial court erred in accepting the prosecution witness testimonies as reliable despite alleged inconsistencies.
- Contended that the physical possibility of his presence at the dance hall was not disproved by his alibi of sea fishing.
- Maintained that he was wrongly grouped with his son in the appeal and that the self-defense claim for his son should have been given weight.
Issues:
- Whether the trial court erred in giving significant credence to the testimonies of the prosecution witnesses (e.g., Boganutan and CaAete), despite alleged inconsistencies, thereby establishing the presence of accused Benny Acosta at the scene of the crime.
- Whether the accused’s alibi, claiming he was sea fishing at the time of the murder, is sufficient and credible, particularly in light of the proximity between his residence and the crime scene.
- Whether the trial court correctly dismissed the defense of self-defense and stranger defense asserted for Renny Boy Acosta, given the circumstances of the victim’s assault and subsequent actions by Renny Boy.
- Whether the inclusion of Renny Boy Acosta in the appeal by accused Benny Acosta was procedurally proper, considering that Renny Boy did not file an appeal and his judgment is already final.
- Whether the award of PHP 50,000.00 as civil indemnity and the modification to include moral damages were properly supported by the evidence, particularly in view of the requirements under prevailing jurisprudence.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)