Case Digest (G.R. No. L-38725)
Facts:
People of the Philippines v. Antonio Artieda, G.R. No. L-38725, May 15, 1979, Supreme Court En Banc, Melencio‑Herrera, J., writing for the Court. This is an automatic review of the Decision of the Court of First Instance of Laguna, Branch IV, which convicted Antonio Artieda of murder and sentenced him to death; his co-accused Rodolfo Artieda and Venancio Dorado were acquitted, and the fourth accused Bernabe (David/Abe) Artieda remained at large.The Information (filed January 30, 1973) charged the four named accused and other "Does" with Kidnapping with Murder for the abduction on the night of May 8, 1972, of Simeon Rivera, alleging the use of firearms, conspiracy, treachery, nighttime, cruelty and superior strength. The trial court, after hearing the prosecution and defense, found only the crime of murder proved and sentenced Antonio to death (Decision dated April 26, 1974), ordering indemnity of P18,000 to the heirs and partial costs; Rodolfo and Venancio were acquitted for insufficiency of evidence.
Prosecution evidence: On May 8, 1972 at about 9:00 p.m., Apolonia Heraldo (wife of the victim) testified that she and her husband were roused by men claiming to be authorities; she identified Venancio Dorado, Rodolfo Artieda and Antonio Artieda as among those who entered, seized Simeon, and bound him; Apolonia said she was physically elbowed and pleaded for her husband’s life. The body of Simeon was found in a forest two days later; medical examination placed time of death at about 2½–3 days earlier and showed multiple stab wounds and that the hands were tied behind the back (photographs and medical certificate admitted). Apolonia delayed formally reporting the identities until May 12, 1972, alleging fear after threats; she initially informed the municipal authorities but did not name the abductors for fear of reprisal.
Defense evidence: Antonio pleaded alibi, presenting Aquilino Carpena who testified he saw Antonio at a fiesta in Rizal, Laguna, at about 10:00 p.m. on May 8, 1972 (Rizal being roughly four kilometers from the crime scene). Antonio later wrote an extrajudicial confession dated January 9, 1979 (during pendency of this appeal) addressed to the Chief Justice admitting he killed Simeon and offering to accept punishment.
The trial court found Antonio positively identified and guilty of murder qualified by treachery and aggravated by cruelty and nocturnity, imposing death under Article 248 in relati...(Pro-only)
Issues:
- Was the identification testimony of Apolonia Heraldo and Mario Pomperada sufficiently reliable to support conviction?
- Was the defense of alibi established with such convincing evidence as to negate the prosecution’s identification?
- Were the qualifying circumstance of treachery and the aggravating circumstances of nocturnity and cruelty proven?
- Does the extrajudicial confession made by appellant during the pendency of the appeal afford the mitigating circumstance of plea of guilty or otherwise affect punishment?
- What is...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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