Case Digest (G.R. No. 105391)
Facts:
The People of the Philippines v. Benedicto Campa, et al., G.R. No. 105391, February 28, 1994, Supreme Court Second Division, Narvasa, C.J., writing for the Court. The prosecution-appellee is the People of the Philippines; the defendants-appellants are Benedicto Campa, Mateo Campa, Proceso Campa, Jimmy Campa, and Dalmacio Campa (collectively, the Campa brothers). Padilla, Regalado, Nocon and Puno, JJ., concurred.On the evening of January 24, 1984, a birthday dance at the home of Benedicto Campa, Sr., in Hacienda Galispin, Barangay Mansilingan, Bacolod City, ended in violence. Guests included Josefino Jagocoy and companions from Hacienda Garcia. After Josefino allegedly insisted on dancing with Mila (the wife of Dalmacio Campa), an altercation ensued; a man identified as Jeorge Villacampa leapt from the Campa house and was pursued. Shortly thereafter Josefino was set upon while standing by a bamboo pole. Witnesses describe Villacampa hacking Josefino with a cane cutter, followed by Dalmacio and Jimmy stabbing him, and the other Campa brothers surrounding and striking him with cane cutters. Josefino was taken to Bacolod Doctors Hospital, identified his attackers to a police investigator before he died the next day, January 25, 1984.
An information dated January 30, 1984 charged Jeorge Villacampa (who remained at large) and the Campa brothers with murder. At the Regional Trial Court (Branch 48, Bacolod City) the prosecution relied principally on eyewitnesses Freddie Mojica and Ricardo Pagunsan, Jr.; the defense offered a version blaming Villacampa as the sole aggressor and produced several defense witnesses whose accounts varied. On January 31, 1989, the trial court convicted the five Campa brothers of murder and sentenced them to life imprisonment, ordering indemnity of P16,000 each. Motions for reconsideration were denied, and the defendants perfected an appeal.
The case arrived at the Supreme Court on appeal from the trial court's ju...(Subscriber-Only)
Issues:
- Was the appellants' conviction supported by credible identification and evidence of a common design, or should the verdict be reversed for insufficiency of proof?
- Did the prosecution prove the qualifying circumstances (treachery or evident premeditation) to warrant a conviction for murder rather than homicide?
- Were the claimed mitigating circumstances (passion/obfuscation and voluntary surrender) properly established?
- Was the penalty of "life imprisonment" pro...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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