Case Digest (G.R. No. 84276)
Facts:
People of the Philippines v. Cresencio Jimenez, Jr., Ronald Jimenez, Cresencio Jimenez, Sr., Jessie Jimenez and Erlinda Paglinawan, G.R. No. 84276, February 13, 1992, Supreme Court Second Division, Paras, J., writing for the Court.On December 3, 1985, Cpl. Carlito P. Asilum, Acting Station Commander of the INP, filed a criminal complaint for murder against the Jimenez family members named above. Municipal Circuit Trial Judge Jacinta B. Tambago found probable cause and ordered warrants of arrest without bail; only Cresencio Jimenez, Jr. and Ronald Jimenez were arrested while the parents and another brother remained at large. On March 6, 1986 the records were forwarded to the Provincial Fiscal of Masbate and, on March 24, 1986, an Information for Murder was filed and docketed as Criminal Case No. 4951 before the Regional Trial Court, Masbate (Branch XLIV).
At arraignment on July 23, 1986, Cresencio Jimenez, Jr. and Ronald Jimenez pleaded not guilty and trial followed. The prosecution presented Dr. Ernesto Tamayo (who performed the postmortem), Teofila Areglado (the victim’s widow and eyewitness), and Rolando Palacay (a hired hand who corroborated the eyewitness account). Dr. Tamayo’s postmortem report showed five fatal wounds inflicted by different weapons. Teofila and Palacay testified that the four male Jimenezes encircled and attacked Pio Areglado; Teofila identified the particular role of each assailant (spear, spear gun, scythe, bolo), and stated that Erlinda Paglinawan (mother) was nearby urging the killing.
In defense, Ronald Jimenez admitted killing Pio Areglado but pleaded self-defense and asserted he acted alone; he also presented evidence of his voluntary surrender. Cresencio Jimenez, Jr. asserted an alibi, claiming he was at home sick at the time of the incident and was arrested later; he said his knowledge of details came from his brother while detained. Police testimony and a blotter entry confirmed Ronald’s voluntary surrender.
On May 4, 1988 the regional trial court convicted Cresencio Jimenez, Jr. and Ronald Jimenez of Murder, sentencing Cr...(Subscriber-Only)
Issues:
- Should the Supreme Court defer to the trial court’s credibility findings and thus affirm the convictions?
- Was Ronald Jimenez’s plea of self-defense established by clear and convincing evidence?
- Did Cresencio Jimenez, Jr. successfully prove his alibi so as to create reasonable doubt?
- Was Ronald’s voluntary surrender a mitigating circumstance sufficient to reduce h...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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