Case Digest (G.R. No. 196735)
Facts:
People of the Philippines v. Danilo Feliciano, Jr., Julius Victor Medalla, Christopher Soliva, Warren L. Zingapan, and Robert Michael Beltran Alvir, G.R. No. 196735, May 05, 2014, Supreme Court Third Division, Leonen, J., writing for the Court.The prosecution charged members of the Scintilla Juris fraternity, including respondents Danilo Feliciano, Jr., Julius Victor L. Medalla, Christopher L. Soliva, Warren L. Zingapan, and Robert Michael Beltran Alvir, in multiple informations arising from a December 8, 1994 campus ambush at the Beach House Canteen, UP Diliman. The principal information (Criminal Case No. Q95-61133) charged murder (the fatality: Dennis F. Venturina) and alleged aggravating circumstances including that the assailants were “wearing masks and/or other forms of disguise.” Separate informations (Q95-61134 to Q95-61138) charged attempted and frustrated murder for injuries sustained by several Sigma Rho members.
At trial the prosecution presented victims and bystanders who testified that a large group armed with baseball bats and lead pipes attacked the Sigma Rho men; some victims said certain attackers’ masks fell off and identified specific accused. Medical and medico-legal evidence (autopsy and examinations) established traumatic head injuries as the cause of Venturina’s death and injuries to other victims. The defense offered numerous witnesses and alibi testimony, and several bystanders and UP police testified they could not identify the attackers because the assailants wore masks.
The Regional Trial Court (Quezon City, Branch 219) tried eleven accused (one remained at large). On February 28, 2002 the RTC convicted five—Alvir, Feliciano, Soliva, Medalla, and Zingapan—of murder and attempted murder and acquitted six others; one accused’s case was archived pending arrest. Because reclusion perpetua was imposed, the case was initially an automatic appeal but, after amendments to the Rules on Appeal, was remanded to the Court of Appeals. After several re-rafflings the Court of Appeals, Special First Division of Five, on December 26, 2010 affirmed the RTC decision (three concurring, one dissenting). The appellate ruling was then brought to the Supreme Court for review.
The Supreme Court framed the contested questions more narrowly as (1) whether including the aggravating circumstance...(Subscriber-Only)
Issues:
- Does alleging the aggravating circumstance of wearing masks in the information violate the accused-appellants’ constitutional right to be informed of the nature and cause of the accusation when testimony shows some masks fell off?
- Did the Regional Trial Court and the Court of Appeals correctly find the accused-appellants sufficiently identified and therefore g...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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