Case Digest (G.R. No. 197360)
Facts:
People of the Philippines v. Ronald Credo aka Ontog, Randy Credo and Rolando Credo y San Buenaventura, G.R. No. 197360, July 03, 2013, Supreme Court Second Division, Perez, J., writing for the Court. The respondent in the criminal action below was the People of the Philippines and the accused-appellants were Ronald Credo (aka Ontog), Randy Credo, and Rolando Credo y San Buenaventura.On 22 June 2005, at about 10:30 p.m. in Barangay San Jose, Pili, Camarines Sur, Joseph Nicolas was attacked and fatally hacked. An amended Information charged the three appellants with murder alleging abuse of superior strength as a qualifying circumstance. The prosecution presented eyewitnesses — Joseph’s son Russel and nephew Francis — who testified that they saw the three appellants, each armed with a bolo, repeatedly hack the victim. Manuel Chica corroborated seeing the three appellants armed together. The medico-legal report showed six hack wounds, one of which was fatal.
At trial appellants denied joint participation and asserted defenses including self-defense and defense of relatives, with testimony from family members claiming Joseph had threatened or attacked. On 14 July 2009, the Regional Trial Court (Branch 31, Pili) found the three appellants guilty beyond reasonable doubt of murder, imposed reclusion perpetua, and awarded damages to the victim’s widow. On appeal, the Court of Appeals in CA‑G.R. CR‑HC No. 04113 (28 February 2011) affirmed conviction but modified the damages: civil indemnity and moral damages increased, exemplary reduced, and temperate damages substituted for actual damages.
While the case was pending before this Court, the Court was notified that appellant Rolando Credo died on 23 June 2011; his...(Subscriber-Only)
Issues:
- Did Rolando Credo’s death while the case was pending extinguish his criminal and civil liability?
- Did the trial court commit reversible error in discrediting the appellants’ claims of self-defense and defense of relatives and in finding them guilty?
- Were the eyewitness testimonies sufficiently credible and consistent to sustain conviction?
- Was there sufficient evidence of conspiracy among the appellants to support conviction?
- Did abuse of superior strength attend the commission of the killing?
- Were the awards of civil indemnity, moral damages, exemplary damages and tempe...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)