Case Digest (G.R. No. 154348-50)
Facts:
People of the Philippines v. Pablo dela Cruz, G.R. Nos. 154348-50, June 08, 2004, Supreme Court First Division, Ynares‑Santiago, J., writing for the Court.The appellant is Pablo dela Cruz (accused); the appellee is the People of the Philippines (prosecution). Three Informations were filed against appellant: Criminal Case No. 12445 charged him with murder (Art. 248, RPC) for the fatal stabbing of Victoriano Francisco on December 15, 1995; Criminal Case No. 12446 charged him with frustrated murder for stabbing Felipe Pajunar the same day; and Criminal Case No. 12452 charged him with frustrated murder for stabbing William Tacaldo. The three cases were consolidated and tried jointly by the Regional Trial Court (RTC), Dumaguete City, Branch 34.
At trial the prosecution presented eyewitnesses — Felipe Pajunar and Juan Florencio — who positively identified appellant as the assailant; Felipe testified appellant embraced him and then stabbed him while whispering “Pinaskuhan nako nimo, Brod.” Victoriano was stabbed and later died; Tacaldo and Florencio were also stabbed and treated in hospital. Police witnesses testified appellant was apprehended fleeing the scene with a hunting knife and was shot in the thigh while resisting arrest; medical witnesses described the wounds and Victoriano’s fatal injuries. Appellant testified he acted in self‑defense after being boxed by a drunken person and claimed he picked up a butcher’s knife to ward off attackers; a defense psychiatrist testified appellant was non‑psychotic though with some paranoia.
The RTC found appellant guilty of murder (Crim. Case No. 12445) and two counts of frustrated murder (Crim. Case Nos. 12446 and 12452), imposing reclusion perpetua for murder and indeterminate penalties for the frustrated murders, and awarding civil indemnity and actual damages. Appellant appealed to the Supreme Court, assigning one error: that the pros...(Subscriber-Only)
Issues:
- Did the prosecution prove appellant’s guilt beyond reasonable doubt, including the presence of treachery?
- What are the correct criminal characterizations and penalties for the acts in each of the three consolidated cases (murder, frustrated murder, attempted murder)?
- Are the awards of civil indemnity, temperate damages and actual damages appro...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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