Title
People vs. Dijan y Macajiya
Case
G.R. No. 142682
Decision Date
Jun 5, 2002
Crispulo Dijan is convicted of murder but the Supreme Court reduces his sentence to homicide due to lack of evidence for treachery, resulting in an indeterminate penalty of nine years and one day of prision mayor to fifteen years and eleven months and three days of reclusion temporal.
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Case Digest (G.R. No. 142682)

Facts:

  • Crispulo Dijan, Romualdo Paglinawan, and Oliver Lizardo were charged with the murder of Alvaro Hilario on April 11, 1998, in Marikina City, Philippines.
  • The Regional Trial Court convicted Dijan of murder, sentencing him to reclusion perpetua, while his co-accused were acquitted due to insufficient evidence.
  • The prosecution alleged that Dijan and his companions attacked Hilario, inflicting fourteen injuries, including nine stab wounds.
  • Dijan claimed he acted in defense of Paglinawan, asserting that Hilario was attacking him.
  • The defense presented testimonies indicating that Hilario was the aggressor, but the trial court found Dijan's defense less credible than the prosecution's evidence.
  • Dijan appealed, arguing that the trial court erred in dismissing his defense and in its evaluation of treachery.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court upheld Dijan's conviction but modified the charge from murder to homicide.
  • The Court determined that while Dijan's actions constituted a crime, the evidence did not adequately support the qualifying circumstance of treachery.
  • Dijan was sentenced to an indeterminate penalty of nine years and one day of prision mayor to fifteen years and eleven months and three days of rec...(Unlock)

Ratio:

  • The Supreme Court observed that the nature and number of wounds inflicted by Dijan on Hilario undermined his claim of acting in defense of a stranger.
  • For a defense to be justifiable, there must be clear evidence of unlawful aggression, necessity of means employed, and absence of malicious intent.
  • Evidence suggested that Hilario was not unarmed and may have posed a threat, as indi...continue reading

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