Title
People vs. Gaddi y Catubay
Case
G.R. No. 74065
Decision Date
Feb 27, 1989
Gaddi convicted of homicide after confessing to killing Esguerra; Supreme Court upheld conviction, downgrading murder to homicide due to insufficient proof of treachery and premeditation.
A

Case Digest (A.C. No. 554)

Facts:

People of the Philippines v. Nerio Gaddi y Catubay, G.R. No. 74065. February 27, 1989, the Supreme Court Third Division, Cortes, J., writing for the Court.

The accused, Nerio Gaddi y Catubay (appellant), was charged with murder for the death of Augusto Esguerra y Navarro in an information alleging stabbing with qualifying circumstances of treachery and evident premeditation. After arraignment Gaddi pleaded not guilty and was tried before Judge Maximiano C. Asuncion of Branch 104, Regional Trial Court, Quezon City.

At trial the prosecution presented five witnesses: Ernesto Guzman, Pat. Arturo Angeles, Cpl. Rogelio Castillo, Pat. Jesus Patriarca, and Dr. Gregorio C. Blanco. Their evidence was that on December 11, 1981 the victim was last seen drinking with the accused at the rear of Ernesto Guzman’s house; on December 12 the accused allegedly told Guzman that he had killed his drinking companion and had dumped the body in a toilet pit; barangay residents apprehended Gaddi, who led police to the pit where the victim’s body was recovered and identified; clothing identified as that worn by the accused during the drinking spree was found in the pit; an extrajudicial (confession) statement by the accused was taken by police (Exh. F) and photos and notes were made (Exhs. C–C5, D).

Gaddi was the lone defense witness. He testified that he left the drinking place to buy gin about 200 meters away and met an acquaintance; upon return he found a bloodstain and later learned from Guzman that the victim had been killed; he denied the killing and claimed his alleged confession was coerced. The trial court convicted Gaddi of murder and sentenced him to reclusion perpetua and ordered indemnity of P50,000 to the heirs.

Gaddi appealed to the Supreme Court, assigning err...(Subscriber-Only)

Issues:

  • Did the trial court err in crediting the testimony of prosecution witnesses (notably Ernesto Guzman) and in disregarding the defense evidence?
  • Did the trial court err in convicting the accused based on his written extrajudicial statement (Exhibit F) which the accused contends was inadmissible?
  • Did the trial court correctly appreciate the qualifying circumstances of treachery and evident premeditatio...(Subscriber-Only)

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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