Case Digest (G.R. No. 233085)
Facts:
People of the Philippines v. Armando Archivido y Abengoza, G.R. No. 233085, September 21, 2020, the Supreme Court Third Division, Gaerlan, J., writing for the Court. The prosecution charged Armando Archivido y Abengoza (accused-appellant) in two separate informations: Criminal Case No. 13933 for the murder of Lilia Archivido y Decerez and Criminal Case No. 13937 for the frustrated murder of Ruben Archivido y Avengoza (his brother), both alleged to have occurred on July 31, 2009 in Brgy. San Pascual, Basud, Camarines Norte. The informations alleged qualifying circumstances including treachery and evident premeditation and accused Armando of using a bladed weapon.Armando admitted to the acts but pleaded self-defense and voluntary surrender. The prosecution's version, supported by witness testimony and medico-legal evidence, was that after a brief argument Armando suddenly hacked Lilia from behind and then attacked Ruben, who later required hospitalization for six hacking wounds. Lilia died of hemorrhagic shock; Dr. Jose Magana performed the post-mortem. Armando claimed that the spouses attacked him first, that his wounds were superficial, and that he went to the barangay hall and police station to surrender.
After pre-trial and a reverse trial, the Regional Trial Court (RTC), Branch 39, Daet, Camarines Norte, rendered a Joint Decision on October 10, 2012 finding Armando guilty of murder (Crim. Case No. 13933) and frustrated murder (Crim. Case No. 13937), sentencing him and awarding damages. Armando appealed to the Court of Appeals (CA). On December 16, 2016 the CA in CA-G.R. CR-HC No. 07306 affirmed the RTC's conviction but modified penalties and awards (it sustained treachery, denied ...(Pro-only)
Issues:
- Was Armando’s plea of complete or incomplete self-defense established by clear and convincing evidence?
- Were the qualifying circumstances of treachery and evident premeditation sufficiently proven for the killing of Lilia and the assault on Ruben?
- If guilty, what penalties and damages should be imposed, and does Armando deserve the mitigating circum...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)