Case Digest (G.R. No. 121828)
Facts:
People of the Philippines charged Edmar Aguilos, Odilon Lagliba y Abregon and Rene Gayot Pilola with the February 5, 1988 killing of Joselito Capa; the Regional Trial Court of Pasig, Branch 164, convicted Rene Gayot Pilola of murder on May 3, 1995 and sentenced him to reclusion perpetua and indemnity of P50,000, prompting this appeal. The prosecution relied on eyewitness Elisa Rolan and the autopsy by Dr. Bienvenido Muñoz showing multiple stab wounds indicating more than one assailant; the appellant pleaded alibi and denied participation.Issues:
- Did the trial court err in finding a conspiracy to kill the victim?
- Did the trial court err in crediting the testimony of prosecution witness Elisa Rolan over the appellant's evidence?
- Was the appellant's guilt proved beyond reasonable doubt?
Ruling:
The Court affirmed the conviction for murder and the sentence of reclusion perpetua, finding the appellant guilty as a principal by reason of conspiracy and, alternatively, by direc Case Digest (G.R. No. 121828)
Facts:
- Case caption and procedural posture
- People of the Philippines as Appellee versus Edmar Aguilos, Odilon Lagliba y Abregon, and Rene Gayot Pilola as Accused; Rene Gayot Pilola as Appellant before the Court.
- Information filed, dated June 7, 1998, charging the three with murder for an alleged February 5, 1988 killing of Joselito Capa y Rulloda, alleging conspiracy, use of knives and bolo, intent to kill, treachery and taking advantage of superior strength.
- Of the named accused, Odilon Lagliba was first arrested, tried and convicted of murder (RTC Decision dated March 19, 1990); Edmar Aguilos remained at large; Ronnie Diamante was reported to have died a month after the incident.
- Appellant Rene Gayot Pilola was arrested, arraigned on March 9, 1994, pleaded not guilty, and underwent trial in RTC, Branch 164, Pasig City.
- Prosecution evidence and incident narrative
- Eyewitness Elisa Rolan testified that on February 5, 1988 at about 11:30 p.m. at 613 Nueve de Pebrero Street, Mandaluyong City, Joselito Capa and Julian Azul, Jr. were drinking when Edmar Aguilos and Odilon Lagliba joined; an argument and fistfight ensued between Edmar and Julian.
- Odilon climbed on hollow blocks, then descended, placed his left arm around Joselito's neck and stabbed him; Ronnie Diamante and appellant Pilola, across the street, saw Odilon stabbing and ran to the scene with knives and also stabbed Joselito; Elisa could not specify who stabbed which part or how many stabs by each.
- The victim fell into the canal; Odilon and appellant fled, Ronnie pursued Julian, then returned and struck Joselito's head with a hollow block and a broken bottle; Joselito died on the spot.
- Prosecution witnesses included Elisa Rolan, Dr. Bienvenido Muñoz, Julian Azul, Jr., and Lydia Clamuha.
- Medical evidence
- Autopsy Report No. N-88-375 by Dr. Bienvenido Muñoz documented multiple contusions, lacerations, incised and eleven stab wounds of varying sizes and directions affecting chest, lungs, heart, spleen, pancreas, ileum and arms.
- Postmortem findings included hemothorax (left) 900 c.c., hemopericardium 300 c.c., hemoperitoneum 750 c.c., pallor of brain and viscera; stomach contained food.
- Cause of death was recorded as Multiple stab wound.
- Dr. Muñoz testified that the wounds indicated use of sharp single‑bladed instruments and opined that there were more than one assailants.
- Defense evidence and testimony
- Appellant Pilola denied stabbing the victim and interposed an alibi, testifying he was at his cousin Julian Cadion's house at 606 Nueve de Pebrero Street at about 11:00 p.m., suffering stomach pain from ulcer.
- Julian Cadion corroborated appellant's presence at the house that night and his alleged illness.
- Witness Agripina Gloria testified she saw Ronnie...(Subscriber-Only)
Issues:
- Principal issues presented on appeal
- Whether the trial court erred in concluding that there was conspiracy among the accused to kill the victim.
- Whether the trial court erred in crediting the testimony of prosecution witness Elisa Rolan despite alleged inconsistencies and in discounting appellant's defense and witnesses.
- Whether the evidence proved appellant's guilt beyond reasonable doubt so as to sustain conviction for murder.
- Subsidiary issues addressed by the Court
- Whether appellant's alibi, supported by his testimony and that of Julian Cadion, was sufficiently proven by clear and convincing evidence.
- Whether appellant, even if not a conspirator, could be held as a principal by direct partici...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
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Doctrine:
- (Subscriber-Only)