Case Digest (G.R. No. 129162)
Facts:
People of the Philippines v. Willy Figuracion, Arcely Figuracion y Fabro, Evangeline Fabro y Tabali and William Esplana y Delgado, G.R. No. 129162, August 10, 2001, Supreme Court En Banc, De Leon, Jr., J., writing for the Court.The four appellants — Willy Figuracion, Arcely Figuracion y Fabro, Evangeline Fabro y Tabali, and William Esplana y Delgado — were charged by information with Murder under Article 248 of the Revised Penal Code for the stabbing death of Cesar Figuracion y Bumatay on July 4–5, 1996 in Quezon City. Upon arraignment the accused pleaded not guilty and moved for bail; after hearings the Regional Trial Court (RTC), Branch 95, denied bail on September 20, 1996 and the case proceeded to trial on the merits.
Prosecution witnesses, principally the victim’s wife Virginia, recounted an afternoon quarrel between Virginia and Arcely over an alleged rumor concerning paternity, and a later nocturnal confrontation during which William allegedly taunted Virginia. A physical struggle ensued outside the victim’s house: William allegedly embraced or restrained Cesar, Arcely and Evangeline were described as holding Cesar’s arms, and Willy was alleged to have stabbed Cesar. Virginia testified she saw Willy stab Cesar while William held Cesar from behind and also wielded a knife. Cesar was taken to Quezon City General Hospital and died the following morning; the medico-legal report and human sketch showed three stab wounds, with the pathologist opining that two different bladed instruments caused the wounds and that two persons inflicted them.
The appellants denied criminal liability. Willy gave an inconsistent account: he initially denied stabbing Cesar and later claimed in redirect that he accidentally stabbed Cesar while wrestling for a knife, invoking self-defense. Arcely, William and Evangeline largely portrayed the events as a brawl and said they did not witness an intentional killing; William and Evangeline said they retired into a house and did not participate in a planned attack.
The RTC, in a Decision dated April 25, 1997 (penalized conspiracy and found treachery, abuse of superior strength and dwelling as aggravating/qualifying circumstances), convicted all four accused of Murder and imposed the death penalty, plus...(Subscriber-Only)
Issues:
- Should the trial court’s credibility determinations and factual findings be disturbed on automatic review?
- Were the appellants properly convicted of Murder, or should their convictions be modified?
- Were qualifying circumstances — treachery, abuse of superior strength, and dwelling — established to sustain a murder conviction?
- Were Arcely Figuracion and Evangeline Fabro y Tabali criminally liable as conspirators in the killing?
- Did Willy Figuracion successfully establish self...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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