Title
People vs. Raquel
Case
G.R. No. L-17401
Decision Date
Nov 28, 1964
A man's conviction for murder is upheld despite his alibi due to credible witness identification and the insufficient basis for motive relevance.
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Case Digest (G.R. No. L-17401)

Facts:

  • On June 1, 1959, Francisco Dador and his wife, Julita Arboso, traveled to barrio Tinambacan, Jaro, Leyte, for a fiesta.
  • They left their home in barrio Catubuan between 3 and 4 PM and arrived in Tinambacan before nightfall, staying with Julita's sister, Segundina Arboso.
  • During supper with twelve guests, a gunshot was heard, and Francisco fell, exclaiming "Aray!"
  • Julita, who was feeding their infant, recognized that her husband had been shot.
  • As she sought help, she encountered the accused, Santiago Raquel, who threatened her, saying, "Your husband will not live again."
  • Francisco later confirmed to Julita that he believed Raquel intended to kill him due to potential testimony against Raquel in a prior case.
  • Francisco was taken to Leyte Provincial Hospital, underwent surgery, but died from his injuries on July 3, 1959.
  • Raquel was charged with murder in the Court of First Instance of Leyte.
  • Raquel presented an alibi, claiming he was cutting grass in another barrio during the shooting.
  • The trial court found the evidence against Raquel compelling, convicted him of murder, and sentenced him to reclusion perpetua, ordering him to indemnify Francisco's heirs.

Issue:

  • (Unlock)

Ruling:

  • The court ruled that the trial court did not err in relying on Julita Arboso's testimony and Francisco Dador's statements regarding the motive.
  • The defense of alibi was not sufficiently established and was correctly rejected by the trial court.
  • The court affirmed t...(Unlock)

Ratio:

  • The Supreme Court upheld the trial court's reliance on Julita Arboso's testimony, highlighting her credible actions in seeking help during a crisis.
  • The court dismissed the argument that her behavior was unnatural, recognizing that reactions to trauma vary among individuals.
  • Julita...continue reading

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