Title
People vs. Garcia
Case
G.R. No. 132915
Decision Date
Aug 6, 2002
Appellant Sunny Garcia and his co-accused Rodel Cristobal are convicted of murder based on circumstantial evidence and positive identification, with the court ruling that conspiracy and abuse of superior strength were present, but finding an error in the trial court's awarding of lost income due to lack of proof.
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Case Digest (G.R. No. 132915)

Facts:

  • The case concerns the murder of Edgardo Benitez on December 31, 1995, in Pasay City, Metro Manila.
  • The accused are Sunny Garcia and Rodel Cristobal, with Garcia appealing the case.
  • On the night of the incident, four men, including Cristobal and Garcia, visited the Benitez residence.
  • Linda Benitez, the victim's wife, heard gunshots and discovered her husband shot and bleeding.
  • Edgardo identified Rodel as the shooter before dying.
  • Linda identified Garcia and Cristobal as part of the group that visited their house.
  • The Regional Trial Court of Pasay City, Branch 114, convicted Garcia and Cristobal of murder, sentencing them to reclusion perpetua and ordering them to pay damages to the victim's widow.
  • Garcia appealed, arguing insufficient evidence, lack of conspiracy, and improper appreciation of the qualifying circumstance of superior strength.

Issue:

  • (Unlock)

Ruling:

  1. The court affirmed Sunny Garcia's conviction, finding the circumstantial evidence sufficient to establish his guilt beyond reasonable doubt.
  2. The court upheld the trial court's finding of conspiracy among the accused.
  3. The cour...(Unlock)

Ratio:

  • The Supreme Court found the combination of circumstantial evidence sufficient to establish Garcia's guilt beyond reasonable doubt.
  • Evidence indicated Garcia and his co-accused went to the victim's house, and the victim was shot shortly after.
  • The court noted that circumstantial evidence could suffice for conviction if it forms an unbroken chain leading to a logical conclusion of guilt.
  • Linda Benitez's testimony, despite minor inconsistencies, was deemed credible and sufficient to identify Garcia as one of the perpetrators.
  • Garcia's alibi w...continue reading

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