Case Digest (G.R. No. 235787)
Facts:
People of the Philippines v. Florenda Manzanilla y De Asis, G.R. No. 235787, June 08, 2020, Supreme Court Third Division, Gaerlan, J., writing for the Court.The accused-appellant, Florenda Manzanilla y De Asis, and one Roberto Gacuma y Cabreana (Roberto) were charged by Information with the crime of parricide for the April 15, 2007 killing of Angel Manzanilla y Saporma. The Information alleged that, conspiring with an unidentified male and with the direct participation of Roberto, the accused-appellant induced or otherwise caused Roberto to shoot the victim in Antipolo City.
Accused-appellant and Roberto were arraigned on May 12, 2012 and pleaded not guilty; trial on the merits followed. During a scheduled hearing the trial court was informed that Roberto had died on November 18, 2010, and the case against him was dismissed per the RTC. The prosecution presented eyewitnesses Mark Lawrence Sarmenta (Mac‑Mac), Ajie Bryle Balandres (Ajie), the victim’s brother Hermie Manzanilla, and Dr. Jose Arnel Marquez (medico-legal officer). Their testimony placed the accused-appellant and Roberto at the scene in Puting Bato, Antipolo on the night of April 15, 2007; Mac‑Mac and Ajie recounted hearing accused-appellant say phrases such as “bilis‑bilisan baka may makakita” and “yariin na,” and described Roberto approaching the victim, escorting him to a dark area and a gunshot shortly thereafter. Dr. Marquez’s autopsy established a fatal gunshot wound entering the right mandibular region and exiting the left lateral neck, consistent with a close-range shot from the victim’s front right side.
The accused-appellant testified she was at home attending her store with her son on the night in question, denied knowing Roberto, and denied participation. The RTC (Branch 72, Antipolo City) found the accused-appellant guilty as principal by inducement and, on November 10, 2015, sentenced her to reclusion perpetua and ordered payment of civil indemnity and exemplary damages. On appeal, the Court of Appeals in CA‑G.R. CR‑HC No. 08336 affirm...(Pro-only)
Issues:
- Did the prosecution prove the accused-appellant’s guilt of parricide beyond reasonable doubt?
- If guilty, was the accused-appellant liable as a principal by inducement, as a co-principal by conspiracy, or both?
- Were the penalty and the awards of civil indemnity, moral and exemplary damages, and temperate ...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)