G.R. No. 178409 - Fadriquelan vs. Monterey Foods Corp.

Arturo de Vera y Carlos – found guilty of homicide under Article 249 of the Penal Code, with the mitigating circumstance of voluntary surrender, and sentenced to an indeterminate penalty of ten years and one day to fourteen years, eight months, and one day of reclusion temporal.
Jaime Caranzo y Catindig (“Jimmy”) – likewise found guilty of homicide under Article 249, sentenced to a minimum of twelve years of prision mayor to a maximum of fourteen years, eight months, and one day of reclusion temporal.
Rosemarie Balignasay – convicted of parricide under Article 246, with a sentence of life imprisonment (later modified to reclusion perpetua).

The decision further ordered that the three accused pay indemnity and damages to the heirs of the deceased Antonio Eugenio, Jr., including actual, moral, and death indemnity damages, aside from the order giving them full credit for preventive imprisonment.

The amended information charged Rosemarie Balignasay with parricide and Jaime Caranzo along with Arturo de Vera with murder. The allegations stated that on or about August 1, 1983, in Quezon City, the accused conspiring together willfully and with evident premeditation stabbed the victim, Antonio Eugenio, Jr., inflicting multiple wounds that directly caused his death.
Evidence Presented:

Dr. Dario L. Gajardo, the major of the PC Crime Laboratory, testified after conducting an autopsy on the victim. His findings detailed multiple stab wounds and abrasions on various parts of the body, including a fatal stab wound on the right chest (measuring 1.9 by 0.5 cm, 8 cm deep, passing through the 2nd intercostal space and lacerating the upper lobe of the right lung).
A medico-legal report and a sketch of the human body indicating the wounds were submitted, as well as the post-mortem certificate listing “cardio respiratory arrest due to shock and hemorrhage secondary to stab wounds” as the cause of death.

Cristina Llanes Vda. de Eugenio, the victim’s mother, described the events surrounding the crime, including details of how the accused forcibly entered the victim’s house, a description of the murderous assault involving stabbing and beating, and her personal observations from where she was at the time.
Patrolman Restituto de Leon recounted his investigative role from the scene, including his issuance of the autopsy request and taking statements from the accused.
Rodrigo Eugenio, the victim’s brother, testified regarding his observations of the incident, including seeing the accused pursuing and engaging with the victim with a bladed weapon.
Additional testimonies, including that of Wilfredo Caranzo and another witness, corroborated aspects of the sequence of events.

The prosecution emphasized a coordinated series of actions: the accused gathering outside the victim’s residence, forcibly entering the house, the victim being chased and wounded repeatedly, and the presence of multiple assailants as evidenced by the various wounds.
The evidence pointed to the unity of criminal purpose and the participation of all the accused, which is key to establishing criminal conspiracy.

Arturo de Vera admitted to killing Antonio Eugenio but claimed he acted in self-defense:

He stated that he went to Jaime Caranzo’s house to invite him for Rosemarie Balignasay’s birthday and on his way home, encountered the victim, who he claimed initially appeared armed before a struggle ensued over a bladed weapon.
He maintained that his actions resulted from a struggle where he wrested the weapon from the victim.

Rosemarie Balignasay denied having any direct role in stabbing her husband and refuted claims that she was seen wielding a piece of wood at the scene.
Jaime Caranzo denied any involvement in the killing:

He testified that on the night of the incident he was at home watching television and later went to the NBI for clearance, offering an alibi that distanced him from the violence.

The defense version also questioned the sequence and location of events, particularly the feasibility of the victim moving several blocks after sustaining the fatal wound, and the reliability of testimonies that positioned the accused at the scene.

The prosecution’s evidence indicated that not only did the accused share a common design but there were several circumstances that supported the existence of a conspiracy.
Contributory factors included:

The fact that Arturo de Vera and Rosemarie Balignasay were living together as husband and wife after Rosemarie separated from the victim.
Testimonies indicating that the trio acted together—Arturo de Vera and Jaime Caranzo engaging in stabbing, while Rosemarie Balignasay was present at the scene, allegedly exhorting them to continue the assault.
The multiple wounds and the complementary roles played by the accused during the crime further corroborated the theory that the fatal attack was a concerted effort stemming from a common design.

Whether the trial court erred in finding that there was sufficient evidence of conspiracy among the accused despite the defense’s contention that there was no controlling motive on the part of Arturo de Vera.

The appellant argued that motive is essential and its absence or the lack of a clear motive negates the establishment of a conspiracy.
The issue centers on whether motive is a controlling factor in proving the participation in a conspiracy or if circumstantial evidence suffices.

The credibility and reliability of the testimonies, particularly in reconciling the inconsistencies in the narrative regarding the location and sequence of the fatal wound inflicted upon the victim.

The appellant challenged the testimony indicating that the fatal wound was inflicted inside the victim’s house, contending it was instead sustained on the street, which would undermine the prosecution’s version of events.

Whether the chain of circumstances and the collective evidence of the actions before, during, and after the incident are sufficient to impute the crime of parricide to Rosemarie Balignasay under the theory that in a conspiracy the act of one is the act of all.

The proper imposition and naming of the penalty for the crime committed by the appellant, specifically whether “reclusion perpetua” should apply instead of “life imprisonment,” in conformity with the Revised Penal Code’s scheme of penalties.