Case Digest (G.R. No. 99840)
Facts:
In People of the Philippines v. Rodolfo Federico y Mediona, G.R. No. 99840, August 14, 1995, the Supreme Court First Division, Davide, Jr., J., writing for the Court, resolved an appeal from a murder conviction. The accused-appellant, Rodolfo Federico y Mediona, was charged in Regional Trial Court (RTC), Branch 49, Manila, with murder in Criminal Case No. 90-82576-SCC and with frustrated murder in Criminal Case No. 90-82577; the two cases were not consolidated.
The RTC, after trial on the merits of Criminal Case No. 90-82576-SCC, found the appellant guilty as a principal of murder in a decision promulgated December 7, 1990, and imposed reclusion perpetua plus civil indemnities; the trial court deemed treachery a qualifying circumstance. The prosecution’s evidence, drawn from eyewitness testimony and autopsy findings, established that on March 17, 1990 Francisco Mediona stabbed Rogelio Fernando and thereafter stabbed Pastor Neil Escala y de Guzman, who died of six stab wounds. Witnesses recounted that Francisco, Ruben Mediona, and the appellant emerged together near the scene; Francisco carried a large knife, while Ruben and the appellant pointed slings and darts toward the group at the bakery prior to the stabbings.
The appellant denied participation, asserting an alibi and claiming police coercion at the precinct. The RTC nonetheless convicted him as a principal on the theory of conspiracy: that the three men shared a common design to kill both Fernando and Pastor Escala and cooperated in its execution. The appellant appealed, contending he did not conspire to kill Pastor Escala and the...(Subscriber-Only)
Issues:
- Was there sufficient evidence to establish a conspiracy between the accused-appellant and Francisco Mediona to kill Pastor Neil Escala y de Guzman, thereby rendering the accused-appellant liable as a principal for murder?
- If no conspiracy to kill Escala was proven, what is the proper characterization of the accused-appellant’s criminal liabi...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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