Case Digest (G.R. No. 181204) Core Legal Reasoning Model
Facts:
The case involves the killing of Diosdado Pido in Barangay Guinciaman, San Miguel, Leyte, on August 24, 2002. Diosdado suffered a total of 26 wounds from a combination of gunshots, stabs, and hacks and died instantly. Edgar Concillado, alongside his wife Dolores Concillado, and brother Erlito Concillado, were charged with murder based on their alleged participation in the attack. The prosecution accused them of conspiring to commit the crime with deliberate intent, treachery, and evident premeditation. During trial before the Regional Trial Court (RTC) in Carigara, Leyte, testimony from Lorenzo Vitas identified Edgar as the shooter, assisted by Dolores stabbing the victim, and Erlito delivering hacking blows. The defense, including Edgar’s admission of inflicting all wounds but claiming self-defense, presented evidences such as Edgar’s injuries and alibi witnesses. The trial court found the accused guilty of murder, sentencing them to death and ordering civil indemnities. On app Case Digest (G.R. No. 181204) Expanded Legal Reasoning Model
Facts:
Incident Details On August 24, 2002, Diosdado Pido was shot, stabbed, and hacked to death in Barangay Guinciaman, San Miguel, Leyte. He sustained a total of 26 wounds, leading to his immediate death. The accused were Edgar Concillado, his wife Dolores Concillado, and his brother Erlito Concillado, who were charged with murder.Prosecution’s Version
The prosecution’s main witness, Lorenzo Vinas, testified that he and the victim attended a fiesta on August 23, 2002. On their way home, Lorenzo witnessed Edgar shoot Diosdado with a homemade gun. After Diosdado fell, Edgar and Dolores stabbed him repeatedly, and Erlito joined in with hacking blows. Lorenzo reported the incident to the barangay tanod.
Defense’s Version
Edgar admitted to killing Diosdado but claimed he acted in self-defense. He alleged that Diosdado attacked him first, and he only defended himself using a homemade gun and a bolo. Dolores and Erlito denied involvement, with Dolores claiming she was asleep and Erlito asserting he was at a fiesta during the incident.
Trial Court Ruling
The Regional Trial Court (RTC) found all three accused guilty of murder, citing conspiracy and evident premeditation. The court rejected Edgar’s self-defense claim, noting the severity and number of wounds on the victim.
Court of Appeals (CA) Ruling
The CA acquitted Dolores and Erlito due to insufficient evidence but convicted Edgar of homicide, not murder, finding that treachery and evident premeditation were not proven. The CA also appreciated the mitigating circumstance of voluntary surrender on Edgar’s part.
Issues:
- Whether Edgar acted in self-defense.
- Whether the qualifying circumstances of treachery and evident premeditation were present.
- Whether Dolores and Erlito conspired in the killing of Diosdado.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)