Title
People vs. Doca y Villaluna
Case
G.R. No. 233479
Decision Date
Oct 16, 2019
Appellant convicted of homicide, not murder, for stabbing a minor; self-defense rejected, voluntary surrender mitigated penalty; damages adjusted.

Case Digest (G.R. No. 233479)
Expanded Legal Reasoning Model

Facts:

  • The Incident and Charges
    • Appellant Jomar Doca y Villaluna was charged with murder for killing Roger C. Celestino, a 17-year-old minor.
    • The killing occurred on or about July 1, 2007 in the Municipality of Solana, Province of Cagayan.
    • The Charge Under Information alleged that appellant, armed with a Rambo knife, attacked, assaulted, and fatally stabbed Roger with evident premeditation and treachery while the victim was unarmed.
  • Proceedings Before the Trial Court
    • The case was raffled to the Regional Trial Court - Branch 4, Tuguegarao City, Cagayan.
    • At arraignment, appellant pleaded “not guilty” and later testified as the lone witness for the defense.
    • The prosecution presented several witnesses including:
      • Rogelio Castro (eyewitness who saw the stabbing incident).
      • Benjamin Cabisora (a relative of the victim and friend of the accused).
      • Dr. Rebecca Battung (who testified on the cause of death related to blood loss).
      • SPO3 Bienimax Constantino and PO3 Roque Binayug (who testified about the recovery of the Rambo knife at the scene).
    • The testimony of the victim’s father, Pablo Celestino, was dispensed with per stipulation regarding the actual damages.
  • The Prosecution’s Version
    • Eyewitness account by Rogelio Castro detailed that:
      • Appellant, found in a waiting shed appearing drunk and angry, was specifically looking for Roger.
      • As Roger passed by, appellant stabbed him in the left breast causing him to collapse and subsequently die.
    • Benjamin Cabisora corroborated that after Roger had walked into the waiting shed, he suddenly fell to the ground.
    • Forensic evidence, as testified by Dr. Battung and supported by police reports, confirmed death by shock secondary to severe hemorrhage from the stab wound.
  • The Defense’s Version
    • Appellant claimed self-defense, asserting that:
      • He was waiting for his friend at a waiting shed when Roger appeared.
      • Roger allegedly attacked him by boxing him and drawing a fan knife (balisong), prompting appellant to wrest the weapon and stab Roger in defense.
    • Appellant contended that his subsequent voluntary surrender further demonstrated his lack of criminal intent.
  • Trial Court’s Ruling
    • The trial court found appellant guilty of murder under Article 248 of the Revised Penal Code.
    • The conviction was based on the prosecution’s presentation of corroborative eyewitness testimonies and evidence.
    • Despite appellant’s admission of having caused Roger’s death with a self-defense claim, the court held he failed to establish the required elements to justify killing.
    • The trial court characterized the killing as having been committed with treachery, despite not finding sufficient evidence of premeditation.
    • Monetary awards were imposed, including civil indemnity, moral damages, exemplary damages, and actual damages.
  • Proceedings Before the Court of Appeals
    • Appellant challenged the trial court’s reliance on eyewitness testimonies and the imputation of treachery.
    • The Court of Appeals, while acknowledging errors such as not crediting the mitigating circumstance of voluntary surrender, nonetheless affirmed the conviction.
    • The appellate court modified the monetary awards by:
      • Deleting the award for actual damages.
      • Increasing the awards for civil indemnity, moral, and exemplary damages.
      • Granting temperate damages along with the imposition of interest on the monetary awards.
  • The Present Appeal
    • Appellant sought an outright reversal, contending errors in the appraisal of witness testimonies and in finding treachery.
    • His primary contention was that his self-defense claim should have led to an acquittal and a dismissal of the murder charge.
    • Both appellant and the Office of the Solicitor General adopted the briefs previously presented before the Court of Appeals.

Issues:

  • Whether the Court of Appeals erred in affirming appellant’s conviction for murder.
    • Did the evidence sufficiently establish the qualifying circumstances of treachery and evident premeditation to qualify the killing as murder?
    • Was appellant’s self-defense claim properly considered in light of the requirement for corroborative evidence of unlawful aggression by the victim?
    • Should the mitigating circumstance of voluntary surrender have been given added weight in reducing criminal liability?
  • The validity of relying solely on the eyewitness testimony of Rogelio Castro amid appellant’s self-serving version.
    • Whether the trial court’s favorable assessment of credibility of eyewitness accounts was warranted.
    • If the absence of additional corroborative evidence invalidated the self-defense plea.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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