Case Digest (G.R. No. 76743)
Facts:
People of the Philippines v. Jaime Caranzo y Catindig alias "Jimmy", Arturo de Vera y Carlos and Rosemarie Balignasay, G.R. No. 76743, May 22, 1992, Supreme Court Third Division, Gutierrez, Jr., J., writing for the Court. The appeal concerns the conviction of Rosemarie Balignasay for parricide and the convictions of co-accused Jaime Caranzo and Arturo de Vera for homicide arising from the stabbing death of Antonio Eugenio, Jr. on August 1, 1983.The amended information charged Rosemarie Balignasay with parricide under Article 246 and Jaime Caranzo and Arturo de Vera with murder (later treated as homicide under Art. 249) for allegedly conspiring to stab and kill the victim. At trial the Regional Trial Court, Quezon City, Branch 99, found all three guilty: De Vera was sentenced under the Indeterminate Sentence Law to prision mayor (10 years + 1 day to 14 years, 8 months + 1 day), Caranzo to prision mayor (12 years to 14 years, 8 months + 1 day), and Balignasay to "LIFE IMPRISONMENT or reclusion perpetua." The trial court also ordered joint and several indemnity and damages and credited the accused with preventive imprisonment.
Prosecution evidence included the medico-legal report and autopsy of Dr. Dario Gajardo describing multiple stab and incised wounds and listing cause of death as cardio-respiratory arrest due to shock and hemorrhage secondary to stab wounds; eyewitness testimony of the victim’s mother Cristina Llanes Vda. de Eugenio placing the appellant and the two men at the scene, describing forced entry, attacks and pursuit culminating at a culvert on Bayani Street where the victim was repeatedly stabbed and where Rosemarie allegedly urged the attackers to continue; police investigation and statements; and testimony of the victim’s brother Rodrigo corroborating parts of the account.
The defense presented a version of self-defense for Arturo de Vera (claiming a struggle for a knife) and denial of participation by Rosemarie and Jaime. Several defense witnesses offered alibi or different sequences of events. Only Jaime Caranzo and Rosemarie filed notices of appeal; Jaime’s appeal to the Court of Appeals is not traced in the records, while Balignasay’s case was forwarded to the Supreme Court because t...(Subscriber-Only)
Issues:
- Was criminal conspiracy established beyond reasonable doubt so as to sustain the conviction of Rosemarie Balignasay for parricide?
- Were the trial court’s factual findings — particularly as to the location and timing of the fatal wound and the credibility of eyewitness testimony — sufficiently supported to reject the defense theory (self-de...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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