Title
Supreme Court
People vs. Amodia
Case
G.R. No. 173791
Decision Date
Apr 7, 2009
Pablo Amodia convicted for 1996 Makati murder; eyewitnesses overruled his alibi, proving conspiracy and abuse of superior strength. Supreme Court affirmed with damages.

Case Digest (G.R. No. 173791)
Expanded Legal Reasoning Model

Facts:

  • Background of the Case
    • Pablo Amodia, together with co-accused Damaso Amodia, George Palacio, and Arnold Partosa, was charged with the murder of Felix Olandria y BergaAo ("the victim") occurring on or about November 26, 1996, at Makati City.
    • The Information alleged that the accused, conspiring and mutually aiding one another, willfully and unlawfully assaulted the victim, beating him with a piece of wood and stabbing him repeatedly, causing fatal wounds.
    • The Information was filed on February 28, 1997, and Pablo was arrested on June 5, 1998. The other accused remained at large.
    • Pablo moved to quash the Information citing mistaken identity and the alleged staleness of the arrest warrant, but the RTC denied the motion.
    • At arraignment on August 3, 1998, Pablo pleaded not guilty.
  • Prosecution’s Evidence and Narrative
    • Eyewitnesses Romildo Ceno (Romildo) and Luther Caberte (Luther), residents and neighbors in the area, testified to having witnessed the assault under the C-5 bridge around 12:05 a.m. on November 26, 1996.
    • Romildo testified seeing the victim being held by Pablo and Arnold on each side, with George striking the victim on the head and Damaso stabbing the victim three times.
    • Luther confirmed the identities of the assailants, including Pablo, and described the physical assault and stabbing. Both witnesses knew Pablo and the victim personally, having been neighbors for years.
    • Following the incident, police investigators found the victim's body at Comembo Bridge, Barangay Pembo. A medico-legal officer performed an autopsy, revealing three fatal stab wounds penetrating the heart, stomach, and pancreas.
    • The post-mortem examination concluded death by hemorrhage secondary to stab wounds inflicted by a single-bladed sharp-pointed instrument.
    • The prosecution also presented testimony from the victim’s father regarding funeral expenses and related damages.
  • Defense’s Version
    • Pablo Amodia claimed an alibi, asserting he was at his sister Elma Amodia Romero's house at the time of the stabbing, located at Zone 13, Ilocos Street, Barangay Rizal, Makati City, where he had resided since 1994.
    • He recounted that his brother Elias’s wife had labor pains, and he was asked to take care of Elias’s children that evening.
    • Pablo testified that Damaso and others, who claimed they encountered trouble, visited Elma's house to pack and then left past midnight for Cebu; Pablo stayed with Elias’s family.
    • Elma and Elias corroborated Pablo's alibi about his presence at their houses during the relevant time frame.
    • Pablo learned about the victim’s death only after returning from school the next day.
    • The defense rested after presenting Pablo's and Elma's testimony and documentary evidence of schooling.
  • Prosecution’s Rebuttal
    • The prosecution presented Amelita Sagarino who testified that she never saw Pablo at the victim’s wake, despite serving food there throughout the night.
    • She also heard from neighbors that the persons responsible included Pablo (also known as Pablito or Pabling Amodia).
  • Lower Courts’ Decisions
    • The Regional Trial Court (RTC) convicted Pablo beyond reasonable doubt of murder as a principal by conspiracy, imposing reclusion perpetua and awarding moral and actual damages to the heirs of the victim.
    • The Court of Appeals (CA) affirmed the conviction but modified the damage awards and clarified the applicable legal provisions. It ordered the award of reclusion perpetua and supplemental damages including civil indemnity and exemplary damages.

Issues:

  • Whether the guilt of the accused-appellant Pablo Amodia for the crime of murder has been proven beyond reasonable doubt.
  • Whether conspiracy existed among Pablo and the co-accused in the commission of the crime.
  • Whether the defense of alibi was sufficiently established to overcome the prosecution’s evidence.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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