Case Digest (G.R. No. 177356)
Facts:
This is People of the Philippines v. Johbert Amodia y Baba, Mario Marino y Patnon, and Roy Lo-oc y Pendang, G.R. No. 177356, November 20, 2008, Supreme Court Second Division, Velasco Jr., J., writing for the Court.The People of the Philippines was the plaintiff-appellee; Johbert Amodia y Baba, Mario Marino y Patnon, and Roy Lo-oc y Pendang were the accused-appellants charged in Criminal Case No. Q-03-118165 before the Quezon City Regional Trial Court (RTC), Branch 89.
On June 10, 2003 at about 3:00 a.m., Richard Avila Roda, an assistant manager of Nognog Videoke Restaurant, went outside and saw seven persons mauling a man. Roda identified three of the assailants as regular customers of the restaurant — later named as Amodia, Marino, and Lo-oc — while the other four assailants and the victim were unknown to him. Roda testified that Lo-oc held the victim’s shoulders while Marino and Amodia took turns beating him; one companion brandished a knife and threatened Roda. The victim fell and Roda observed blood oozing from the back of the victim’s head; he intervened to prevent another blow, after which the three accused returned inside the restaurant and drank beer. Roda did not immediately report the incident, claiming he had been threatened and feared for his safety; he later accompanied the restaurant owner home and only reported the incident two days later at Camp Karingal upon advice from the La Loma Police Station. The victim, later identified as Jaime Bartina, was found alive at the hospital but died that same day at about 5:00 p.m.
On June 12, 2003, police investigation followed Roda’s statement and an Information was filed charging the three accused with murder, alleging conspiracy with four unidentified persons and alleging evident premeditation, treachery, and abuse of superior strength; the Information also noted that Johbert Amodia was a minor (17) at the time. The accused pleaded not guilty and interposed alibi defenses. Lo-oc claimed he had found a man slumped and attempted (unsuccessfully) to get help from the other two, who refused because pedicabs were not allowed on the highway; the three denied participating in the mauling.
On August 24, 2005 the RTC (Branch 89) convicted all three of murder, sentenced Johbert (the minor) to reclusion temporal under a mitigated regime and Marino and Lo-oc to reclusion perpetua, and ordered joint and several civil damages. The Court of Appeals (CA) in CA-G.R. CR-H.C. No. 01628 affirmed the RTC’s decision in a January 23, 2007 decision, giving weight to Roda’s positive eyewitness identification and finding abuse of superior strength to qualify the killing...(Pro-only)
Issues:
- Did the trial court and the Court of Appeals gravely err in giving full weight and credence to the prosecution eyewitness’s testimony?
- Was the guilt of the accused proven beyond reasonable doubt?
- If the accused were guilty, was the conviction properly for murder rather t...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)