Case Digest (G.R. No. 141518)
Facts:
People of the Philippines v. Clarence Astudillo, Crisanto Astudillo, alias Anteng or Enteng, and Hilario Astudillo, G.R. No. 141518, April 29, 2003, Supreme Court First Division, Ynares‑Santiago, J., writing for the Court.The prosecution charged appellants Clarence, Crisanto and Hilario Astudillo by Information with murder for the November 12, 1995 stabbing death of Silvestre Aquino, Jr., alleging conspiracy, treachery and evident premeditation while armed with a sharp instrument; a tricycle used to flee was recovered. After arraignment on November 21, 1995, the appellants pleaded not guilty and trial ensued. Eyewitnesses Manuel Bareng (12) and Eduardo Bata (11) testified they saw Clarence stab the victim repeatedly with a bolo while Crisanto and Hilario held the victim’s wrists; the victim was later pronounced dead. The autopsy report showed 15 stab wounds and cardiac tamponade as cause of death.
The appellants claimed self‑defense: they said the victim had assaulted Clarence with a bottle and that Hilario stabbed him only after being attacked and to repel aggression; the three surrendered to police the same night. On March 16, 1998, the Regional Trial Court (RTC), Branch 2, Bangued, Abra, convicted the appellants of murder qualified by abuse of superior strength and imposed reclusion perpetua plus civil damages. The RTC denied appellants’ motion for reconsideration but issued an Amended Decision replacing “abuse of superior strength” with “treachery” and adjusting penalties and damages; a...(Subscriber-Only)
Issues:
- May the trial court amend its judgment on motion for reconsideration to substitute the qualifying circumstance of treachery for abuse of superior strength without violating double jeopardy or the rules on modification of judgment?
- Did the prosecution prove appellants guilty beyond reasonable doubt of murder (and conspiracy), thereby negating the plea of self‑defense?
- Were the attendant circumstances — treachery, use of motor vehicle (aggravating), and voluntary surrender (mitigating) — properly appreciated?
- Were th...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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