G.R. No. L-6589 - Caraecle vs. Court of Appeals

Case Digest (G.R. No. L-6589)
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Facts:

Overview of the Case

The case involves six accused—Melanio del Castillo, Hermogenes del Castillo, Arnold Avengoza, Felix Avengoza, Rico del Castillo, and Joven del Castillo—who are related by consanguinity or affinity.
The accused were collectively charged with three counts of murder arising from the deaths of three victims: Sabino Guinhawa y Delgado (alias Benny), Graciano Delgado y Aguda (alias Nonoy), and Victor Noriega y Blanco.

Chronology and Location of the Incident

Date and Time: The incident occurred on or about March 21, 2000, around 9:00 o’clock in the evening.
Place: The crime occurred at Sitio Bulihan, Barangay Balete, Batangas City, Philippines.
Manner of the Crime:

The accused were alleged to have acted in concert while armed with bolos (machetes), a kitchen knife, and a pointed instrument—all deadly weapons.
They were accused of willfully, unlawfully, and feloniously attacking, assaulting, hacking, and stabbing the victims with treachery and abuse of superior strength.
The assailants surrounded the victims, with each playing a distinct role as described by eyewitness testimony.

Proceedings in Lower Courts

Consolidation and Arraignment:

Three criminal cases (Criminal Case Nos. 10839, 10840, and 10841) were filed and consolidated for arraignment and trial in the Regional Trial Court (RTC), Branch 4, Batangas City.
On April 7, 2000, the accused pleaded not guilty to the charges.

Evidence Presented by the Prosecution:

Eyewitness Testimony:

PO3 Froilan R. Perfinian testified that he observed the entire incident, identified each alleged participant, and recounted how the accused attacked the victims.

ii. He described that Arnold stabbed Graciano, Rico hacked at Graciano, and that other accused pursued or attacked the fleeing victims.

Supporting Physical and Documentary Evidence:

The discovery of blood-stained clothing, bolos, knives, and other items by police near the crime scene and in the residences connected to the accused.

ii. Post-mortem reports by Dr. Luz M. Tiuseco which detailed multiple hack and stab wounds, thereby corroborating the eyewitness account.

Additional Witnesses:

Accounts from PO3 Pablo Aguda, Sr. Inspector Marcos Barte, SPO3 Felizardo Panaligan, SPO3 Danilo Magtibay, and others were utilized to reconstruct the events and link the accused to the crime.

Version of the Accused and Their Defense

While all admitted to being present in Bulihan at the time of the incident, the accused offered varying defenses:

Melanio, Hermogenes, Felix, and Rico interposed denial.

ii. Arnold and Joven, in particular, admitted their involvement in the killings but invoked self-defense and defense of strangers.

Supporting Testimony for the Defense:

Winifreda del Castillo, the wife of Hermogenes, corroborated the narrative of Arnold and Joven, asserting that they were responding to an immediate threat during an altercation involving her.

Decisions of the Lower Courts

RTC Decision (October 23, 2001):

All accused were convicted of murder.
Sentences imposed:

Arnold, Felix, Rico, Joven, and Melanio were sentenced to reclusion perpetua with accessory penalties.

ii. Hermogenes received a lesser sentence (Fourteen years, Eight months, and One day as minimum to Twenty years of reclusion temporal) due to the recognition of his voluntary surrender as a mitigating circumstance.

Civil liabilities were also imposed, ordering the accused to indemnify the heirs of the victims for actual funeral expenses and moral damages.

Court of Appeals (CA) Decision (April 28, 2005):

The accused raised several issues, including claims that self-defense and defense of strangers should absolve them and that conspiracy was not proven.
The CA affirmed the convictions but modified the award of damages and the penalty imposed on Hermogenes.
Adjustments were made regarding the amounts for civil indemnity, moral damages, actual (temperate) damages, nominal (converted to temperate) damages, and exemplary damages, in conformity with prevailing jurisprudence.

Issues:

Allegations on Admissions and Self-Defense

Whether the admissions by two of the accused (Arnold and Joven) in killing the victims were sufficient to exonerate the remaining accused from criminal liability, given their alleged status as co-conspirators.
Whether Arnold and Joven’s invocation of self-defense and defense of strangers is legally tenable under the circumstances.

Evaluation of Evidence and Credibility

The weight to be given to PO3 Perfinian’s eyewitness testimony versus the denials and alternative versions offered by the accused.
Whether the accused’s subsequent conduct (such as fleeing the scene and disposing of evidence) undermines their credibility and supports the prosecution’s case.

Establishment of Conspiracy and Abuse of Superior Strength

Whether the elements of conspiracy, namely a common design to commit the felony and collective action during the commission of the crime, were satisfactorily established.
Whether the circumstance of abuse of superior strength—manifested by the number of assailants and the use of deadly weapons—appropriately qualifies the killings as murder.

Quantum of Civil Damages

Whether the awards for actual, moral, temperate, and exemplary damages as determined by the lower courts are in line with prevailing jurisprudence and just compensation for the heirs of the victims.

Ruling:

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Ratio:

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Doctrine:

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