Case Digest (G.R. No. 114032)
Facts:
People of the Philippines v. Ignacio Camahalan, Aurelio Tabacon and Pablito Tocmo, G.R. No. 114032, February 22, 1995, First Division, Davide, Jr., J., writing for the Court. On the evening of March 25, 1988, Anatalio Lor was found dead of multiple stab and lacerated wounds; post-mortem findings established eleven stab wounds, six of which were fatal. An information for murder (with alleged evident premeditation and treachery) was filed on August 25, 1988 in Branch 25, Regional Trial Court (RTC), Maasin, Southern Leyte, against Ignacio Camahalan, Aurelio Tabacon, and Pablito Tocmo.The RTC, in a decision dated October 30, 1990 (promulgated December 13, 1990), acquitted Pablito Tocmo for reasonable doubt but convicted Ignacio Camahalan and Aurelio Tabacon, finding treachery as qualifying circumstance; Ignacio was credited with the mitigating circumstance of voluntary surrender and both were ordered to pay P30,000 indemnity jointly and severally. The RTC held Tabacon liable only as an accomplice.
Ignacio and Aurelio appealed to the Court of Appeals (docketed CA-G.R. CR No. 11094). On February 24, 1994 the Court of Appeals reversed in material respects: it found both appellants guilty as principals of murder and imposed reclusion perpetua on each, increased the indemnity to P50,000, and denied Ignacio the mitigating circumstance of voluntary surrender. Because the penalty exceeded the maximum of reclusion temporal, the Court of Appeals certified the case to the Supreme Court under the second paragraph of Section 13, Rule 124 of the Rules of Court for final determination.
After briefing and supplemental assignments of error (challenging reliance on certain witnesses, the finding of treachery, and the denial of voluntary surrender), the m...(Pro-only)
Issues:
- Did the accused- appellants prove self-defense (Ignacio) and defense of a stranger (Aurelio) by clear and convincing evidence?
- Was treachery present so as to qualify the killing to murder?
- Was Ignacio entitled to credit for voluntary surrender?
- Did the trial court err in crediting the prosecution witnesses (notably Rober...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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