Case Digest (G.R. No. 121562)
Facts:
In People of the Philippines v. Ronnie Quitlong y Frias et al. (G.R. No. 121562, July 10, 1998), an information for murder was filed on October 25, 1994 in the Regional Trial Court of Baguio City, Branch 5, against accused-appellants Salvador Quitlong y Frias, Ronnie Quitlong y Frias, Emilio Senoto, Jr. y Pascua, and other John Does for the stabbing death of 19-year-old Jonathan Calpito on the evening of October 20, 1994 along Harrison Road in Baguio City. The information was later amended to add Jesus Mendoza, who remained at large, following affidavits suggesting his participation. The prosecution presented eyewitnesses Lito Adjaro and Herbert Soriano, police officers who found Calpito bleeding and recovered a bloodstained knife (Exh. B), and medico-legal evidence of a through-and-through stab wound to the left ventricle resulting in hypovolemic shock. The defense moved for reinvestigation, denied participation, and offered testimony that Mendoza alone inflicted the fatal blowCase Digest (G.R. No. 121562)
Facts:
- Case Background
- On October 20, 1994, an information for murder was filed in the RTC of Baguio City, Branch 5, against Ronnie Quitlong y Frias, Salvador Quitlong y Frias, Emilio Senoto, Jr. y Pascua, and other John Does, for the stabbing death of Jonathan Calpito y Castro.
- Accused moved for reinvestigation, claiming Jesus Mendoza was the actual stabber; City Prosecutor filed an amended information on December 12, 1994, adding Mendoza as a co-accused.
- The Stabbing Incident
- In the evening of October 20, 1994, after a dispute over short change at a fishball stall, Calpito and companion Gosil walked to Harrison Road. Eight men, including the three appellants, approached and cornered Calpito.
- Witnesses Lito Adjaro and Herbert Soriano saw:
- Emilio Senoto holding Calpito’s body from behind.
- Salvador Quitlong holding Calpito’s right hand.
- Ronnie Quitlong holding Calpito’s left hand and then stabbing him once at the left thorax below the nipple.
- Police intervention led to the arrest of the three appellants; a bloodstained steel knife (Exh. B) was recovered at the scene.
- Medical and Ancillary Evidence
- Victim was rushed to Baguio General Hospital but died at 8:55 PM.
- Autopsy by Dr. Kathryna Ayro revealed a through-and-through stab wound of the pericardium and left ventricle, causing hypovolemic shock.
- The family incurred P37,500.00 in funeral expenses; mother Precy Calpito testified to moral suffering.
- Trial Court Proceedings
- Prosecution presented eye-witness testimonies of Adjaro, Soriano, police officers, and the medico-legal officer.
- Defense admitted appellants’ presence at the scene but denied participation, introducing alibi and witnesses claiming Mendoza was the sole stabber.
- RTC found appellants acted in conspiracy, convicted all three of murder with indeterminate penalties (20 to 40 years) and awarded civil indemnity, actual and moral damages.
Issues:
- Whether conspiracy was properly alleged in the information, such that appellants could be convicted as co-principals.
- Whether the crime charged and proved is murder or only homicide.
- Whether the trial court erred in convicting the accused-appellants of murder instead of homicide.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)