Case Digest (G.R. No. 146247)
Facts:
People of the Philippines v. Edgar Dawaton, G.R. No. 146247, September 17, 2002, Supreme Court En Banc, Bellosillo, J., writing for the Court.The accused-appellant is Edgar Dawaton; the prosecution is the People of the Philippines. An Information for murder qualified by treachery and evident premeditation was filed against Dawaton on March 11, 1999. At arraignment he pleaded not guilty; during pre-trial (May 7, 1999) he offered to plead guilty to the lesser offense of homicide but the prosecution rejected the offer, and the case proceeded to trial before the Regional Trial Court (RTC), Branch 96, Baler, Aurora (Decision penned by Judge Rebecca R. Mariano).
At trial the People presented as eyewitnesses Domingo Reyes and Esmeraldo Cortez, who were with the accused and the victim, Leonides (Levares/Lavares), during the incident of September 20, 1998. The prosecution also presented the victim’s mother, Generosa Tupaz, for civil liability. Evidence showed the parties drank heavily throughout the day; while the victim slept on a bench, Dawaton left briefly, returned with a knife and stabbed the sleeping victim repeatedly until death. The two witnesses testified they were a few meters away, shocked and unable to prevent the killing. Dawaton was arrested soon after at his uncle’s house.
The defense rested on Dawaton’s lone testimony that he was intoxicated, had been threatened by the victim with a grenade and acted to prevent the threatened harm; he admitted stabbing the victim three times and claimed partial loss of recollection thereafter. The medico‑legal certificate (admitted by stipulation) showed multiple stab wounds and hypovolemic shock as cause of death. On November 20, 1999 the RTC convicted Dawaton of murder qualified by treachery and sentenced him to death, ord...(Subscriber-Only)
Issues:
- Was the crime of murder, as charged, proven beyond reasonable doubt?
- Did treachery attend the killing?
- Were the mitigating circumstances claimed by the accused—(a) offer to plead guilty to a lesser offense, (b) voluntary surrender, (c) outraged feelings analogous to passion, and (d) non‑recidivism—present and sufficient to reduce the penalty?
- Did the accused’s intoxication qualify as a mitigating circumstance that would reduce the penalty from death to reclusion perpetua?
- Are civil indemnity and moral damages pr...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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