Title
People vs. Dijan y Macajiya
Case
G.R. No. 142682
Decision Date
Jun 5, 2002
Three men were charged with murder after a fatal stabbing; Dijan was convicted of homicide, not murder, due to insufficient evidence of treachery, with modified penalties and damages.

Case Digest (G.R. No. 142682)

Facts:

People of the Philippines v. Crispulo Dijan y Macajiya, G.R. No. 142682, June 05, 2002, the Supreme Court First Division, Vitug, J., writing for the Court.

The case arose from the killing of Alvaro Hilario on the night of 11 April 1998 in Parang, Marikina City. Police charged Crispulo Dijan y Macajiya (accused-appellant) together with Romualdo Paglinawan and Oliver Lizardo for murder before the Regional Trial Court (RTC), Branch 272, Marikina, by an information alleging they conspired, were armed with a knife and an ice-pick, and used treachery in stabbing Hilario.

Prosecution witnesses, including Roderick Silvestre (a companion of the victim) and responding policemen, testified that after an initial verbal encounter the three accused allegedly waited for Hilario and Silvestre, then ganged up on and took turns stabbing Hilario; Silvestre fled and policemen found Hilario dead. The medico-legal officer testified to multiple stab, puncture and incised wounds consistent with two single-bladed weapons and an icepick.

The defense account, offered separately by Dijan and his co-accused, described an initial apology and reconciliation after a confrontation; they asserted that Hilario stabbed Paglinawan first, that there was a struggle over the weapon(s), that Silvestre was armed with an icepick, and that Dijan intervened to aid Paglinawan by disarming Silvestre and thereafter stabbing Hilario in the course of defending a companion. Defense witnesses Lani Sarmiento and Dr. Alfredo Garcia corroborated that Paglinawan had been stabbed and treated for a right forearm wound at Amang Rodriguez Medical Centre.

The RTC convicted Crispulo Dijan of murder qualified by treachery and sentenced him to reclusion perpetua, while acquitting Paglinawan and Lizardo for reasonable doubt; the RTC also ordered indemnity, funeral expenses and moral/exemplary damages. Dijan appealed to this Court, arguing (1) the RTC erred in fi...(Subscriber-Only)

Issues:

  • Did the trial court err in finding Crispulo Dijan guilty beyond reasonable doubt of the crime of murder?
  • If the accused is guilty, was the qualifying circumstance of treachery properly appreciated by ...(Subscriber-Only)

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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