Title
People vs. Macaraig y Gonzales
Case
G.R. No. 219848
Decision Date
Jun 7, 2017
Macaraig stabbed Joven Celeste from behind during a dance party, leading to Joven's death. Despite Macaraig's self-defense claim, the Supreme Court affirmed his murder conviction, citing treachery and Joven's dying declaration.

Case Digest (G.R. No. 219848)

Facts:

  • Incident and Criminal Charge
    • On May 31, 2011, in Barangay Salvacion, Baybay, Calabanga, Camarines Sur, the accused-appellant Godofredo Macaraig y Gonzales was charged with the crime of murder.
    • The charge stemmed from the allegation that, with intent to kill, he attacked and stabbed Joven Celeste y Malanyan using a bladed instrument while the victim was unprepared and exposed.
    • The stabbing, committed with treachery, was said to have been deliberately executed by approaching the victim from behind, placing his left arm over the victim’s shoulder, and using his right hand to inflict a fatal wound.
  • Prosecution’s Version of Events
    • The events unfolded during the early hours after a Sta. Cruzan celebration:
      • Francis Losano, a friend of the victim, accompanied Joven Celeste as they left a basketball court during the celebration.
      • Losano observed that the accused-appellant was following Joven, and subsequently, witnessed him approach from behind and stab the victim.
    • Subsequent Reactions and Actions:
      • After the stabbing, the accused-appellant fled into a rice field upon noticing Francis Losano, who then pursued him armed with a bolo and flashlight.
      • Joven, despite his injuries, managed to get home and then sought help from his parents, leading to his transfer to a hospital.
    • Witness Testimonies and Medical Findings:
      • Herson Heles, the victim’s cousin, testified regarding Joven’s dying declaration in the ambulance en route to the hospital where Joven identified the accused as his assailant.
      • Dr. Daniel Tan described the wound as an 8 cm. x 3 cm. stab wound in the midepigastric area, which penetrated vital organs including the liver, abdominal aorta, and small intestine, with blood pooling in the peritoneal cavity.
      • The testimonies collectively converged to support the claim that the attack was sudden, premeditated, and carried out with treachery.
  • Defense’s Version of Events
    • Accused-Appellant’s Account:
      • Godofredo Macaraig claimed that on the night of May 31, 2011, he was en route to a friend's (Jeffrey Crobalde’s) residence in Sogod, Calabanga, following an earlier invitation.
      • He stated that prior to reaching his destination, he was trailed by two unidentified men while another unidentified man waited for him.
    • Allegation of Self-Defense:
      • Macaraig contended that during the incident, an unidentified assailant (or alternatively the victim’s companion) initiated an attack by wielding a balisong.
      • He claimed that he evaded the initial blows and that it was not he who stabbed Joven but rather an unknown individual.
      • His version lacked clarity regarding the identity of the aggressor and the exact dynamics of the confrontation.
  • Procedural History
    • Regional Trial Court (RTC) Decision:
      • On October 16, 2013, the RTC of Calabanga, Camarines Sur, Branch 63, rendered judgment finding the accused guilty of murder.
      • The RTC imposed the penalty of reclusion perpetua and ordered the payment of various damages to the heirs of the victim, including civil indemnity, moral, actual, and exemplary damages.
    • Court of Appeals (CA) Decision:
      • On November 20, 2014, the CA affirmed the RTC’s decision in its entirety.
      • The appellate decision upheld the conviction and the imposition of the penalties without any modifications regarding the crime charged.
    • Supreme Court Ruling:
      • The accused-appellant filed a petition arguing that the lower courts erred in convicting him and in disregarding his self-defense claim.
      • The Supreme Court, after a comprehensive review, sustained the conviction and dismissed the appeal, modifying only the award for moral and exemplary damages.

Issues:

  • Whether the trial and appellate courts erred in convicting the accused-appellant of murder based on the presented evidence.
  • Whether the accused-appellant’s claim of self-defense has merit and if he sufficiently proved the requisite elements thereof.
  • Whether the factual and circumstantial evidence, including the testimonies and medical findings, establish beyond reasonable doubt the commission of murder with treachery.
  • Whether the modifications in the award for damages (moral and exemplary) are appropriate in the context of the case.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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