Title
People vs. Aguilar
Case
G.R. No. 120622-23
Decision Date
Jul 10, 1998
Aguilar, drunk, killed two women in a hotel room, claiming self-defense. Convicted of homicide, not murder, due to insufficient proof of treachery. Damages adjusted.
A

Case Digest (G.R. No. 120622-23)

Facts:

On or about December 2, 1994, in the Municipality of Malabon, Metro Manila, Noel Aguilar y Amistuso was charged in two separate Informations with the deaths of Helen A. Revilla and Angelina Pascua y Rana. In the morning of the incident, the accused and two companions had a drinking spree at Virgo Pubhouse along MacArthur Highway, Potrero, Malabon, where two female receptionists, Helen and Angelina, entertained them. Around 6:00 a.m., the accused paid the bill of P587.00. Helen told a waiter that she would leave to sleep. A taxi driver, Roberto Laxa, saw Helen, Angelina, and a male companion proceed about fifteen to twenty meters away to Lampara Hotel. Laxa later observed Angelina come out alone and board a jeep to Valenzuela, returning shortly after. While waiting for Helen and Angelina to come out so he could retrieve his Ray-ban glasses entrusted as security for a loan, Laxa entered the hotel and talked to hotel employees, including roomboys Inigo Malapitan, Jun Eusebio, and Rodolfo Barreto. He learned that the trio checked in at Room 239. Shortly afterward, the male companion hurried past the counter toward MacArthur Highway, looking pale and leaving Helen and Angelina behind. Roomboy Malapitan went to Room 239 to clean and immediately came out shouting about bloodied bodies lying on the floor. Barreto tried to chase the man, but he was no longer to be found. During investigation, Malabon policemen found a wallet containing an identification card with the name Noel Aguilar, among others; the photograph in the ID was shown to Laxa and to the hotel employees, who identified the man as the one who checked in and as the one who most probably killed the two women. The police later arrested the accused in Bahay Toro, Quezon City. In court, Laxa and the roomboy Barreto identified the accused as the male companion who checked in with Helen and Angelina in Room 239. Autopsy results showed that Helen died of multiple stab wounds inflicted on different parts of her body, including her front, left side, and back, with fourteen stab wounds, and that she was six months pregnant. Angelina also sustained multiple stab wounds, with twenty-nine injuries on the front and back. The parents of Helen and Angelina each sought damages for death and burial, and moral damages for pain and sorrow. The accused denied culpability for murder and gave a different narrative, claiming that after drinking he was taken to a room at Lampara Hotel, where someone entered and stabbed or pressed a sharp pointed object near his armpit; he further alleged that someone attempted to get his wallet with P4,000.00, that he fought back, wrested the instrument, and swung it in self-defense, and that the assailants were Helen and Angelina who, in the struggle, sustained stab wounds. The trial court rejected the accused’s version, found him guilty of two counts of murder, imposed two terms of reclusion perpetua, and ordered indemnity, actual damages, and moral damages. On appeal, the accused challenged the trial court’s conclusions on self-defense, treachery, and the murder convictions, including the failure to acquit him.

Issues:

Whether the accused’s convictions for two counts of murder could stand in light of the alleged self-defense and the claimed lack of treachery, and whether the trial court correctly awarded the moral and actual damages.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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