Case Digest (G.R. No. 130492)
Facts:
People of the Philippines v. Salvador Arrojado, G.R. No. 130492, January 31, 2001, Supreme Court Second Division, Mendoza, J., writing for the Court.The information charged accused-appellant Salvador Arrojado with murder for allegedly stabbing his cousin Mary Ann Arrojado multiple times on or about June 1, 1996 at their residence in Roxas City; he pleaded not guilty and stood trial before the Regional Trial Court (RTC), Branch 19, Roxas City. The RTC conducted a full trial with testimonial and medico-legal evidence, found the accused guilty beyond reasonable doubt of murder, and on April 21, 1997 sentenced him to thirty (30) years (stated as “30 years of reclusion perpetua” in the judgment) and ordered payment of civil indemnity, moral damages and costs.
At trial the prosecution introduced the victim’s death certificate and autopsy report by Dr. Ma. Lourdes Roldan showing ten stab wounds (several of them fatal) and listing hemorrhagic shock from multiple stab wounds as the cause of death; a kitchen knife found near the body; photographs and a sketch of the crime scene; and family witnesses who testified to the strained relationship between accused and victim and who described the house as locked with windows grilled. The defense advanced suicide or the possibility of an intruder as alternative explanations and produced the accused’s own testimony that he found the victim dead and that the knife was a kitchen utensil familiar to him.
The RTC convicted on circumstantial evidence, finding treachery and abuse of superior strength as qualifying circumstances but no evident premeditation; it imposed 30 years of reclusion perpetua and awards of P60,000 (civil indemnity) and P80,000 (moral damages). The accused appealed; the case came to the Supreme Court on appeal where the Court reviewed the sufficiency of the circumstantial evidence, w...(Subscriber-Only)
Issues:
- Did the trial court err in finding that the victim sustained ten stab wounds and in accepting the medico-legal findings over lay observations?
- Did the trial court err in ruling that the victim could not have committed suicide?
- Did the trial court err in concluding that no intruder could have entered the house because doors and windows were locked and therefore only an occupant could be the assailant?
- Were qualifying and aggravating circumstances properly appreciated (treachery; abuse of confidence) and was the penalty properly imposed given the allegations in the information and applicable procedural rules? ...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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