Case Digest (G.R. No. 177223)
Facts:
People of the Philippines v. Castor Batin, G.R. No. 177223, November 28, 2007, Supreme Court Third Division, Chico‑Nazario, J., writing for the Court.The Information, filed 11 April 1995 by the Office of the City Prosecutor of Quezon City, charged Castor and his son Neil Batin with murder for the shooting of Eugenio Refugio on 21 October 1994 while the victim was leaning against a mango tree in Novaliches, Quezon City. Both accused pleaded not guilty. The prosecution presented eyewitnesses (Josephine Refugio, Eusebio Farrales, Vilma Juadinez Rodriguez and others), medico‑legal and ballistics evidence showing the bullet recovered was fired from the specimen firearm; the defense presented Neil, Castor’s common‑law wife Maricon Pantoja, and another witness.
At trial the trial court found the prosecution witnesses credible, disbelieved Neil’s account of an accidental discharge—observing that the revolver was double‑action and would not fire accidentally without cocking—and concluded that Castor and Neil conspired in the shooting and that treachery attended the killing. On 8 June 1998 the Regional Trial Court of Quezon City convicted both Castor and Neil of murder (qualified by treachery), sentenced them to reclusion perpetua, and awarded civil indemnities and damages.
Neil filed an appeal but later filed an Urgent Motion to Withdraw Appeal which was granted on 13 November 2000. Castor appealed to the Court of Appeals. On 6 February 2007 the Court of Appeals in CA‑G.R. CR HC No. 01396 affirmed the conviction but modified the civil awards (reducing moral damages to P100,000 and increasing loss‑of‑earning indemnity to P723,840). Castor then elevated the case to the Supreme Court seeking reversal of his conviction or, in the alternative, conviction only for homicide and reduc...(Subscriber-Only)
Issues:
- Was Castor properly convicted as a principal (by inducement or by conspiracy) in the killing of Eugenio Refugio?
- Was the qualifying circumstance of treachery sufficiently alleged in the Information?
- Were the civil liabilities (death indemnity, actual damages, moral damages, and indemnity for loss of earning capacity) corr...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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