Title
People vs. Rarugal
Case
G.R. No. 188603
Decision Date
Jan 16, 2013
Appellant convicted of murder for stabbing victim during robbery; treachery proven, alibi rejected. Damages awarded, including P75,000 civil indemnity.
A

Case Digest (G.R. No. 188603)

Facts:

  • Parties and case initiation
    • People of the Philippines filed an information on December 8, 1998, for the crime of murder against Ramil Rarugal alias Amay Bisaya alleging that on October 19, 1998 in Quezon City he stabbed Arnel M. Florendo with intent to kill, qualified by evident premeditation and treachery.
  • Arrest, arraignment and plea
    • Appellant was arrested in August 2001 and arraigned on August 27, 2001, when he pleaded not guilty.
  • Facts as found by the trial court regarding the incident
    • On the night of October 19, 1998, at about 9:45 p.m., victim Arnel M. Florendo was cycling along Sampaguita Street, Barangay Capari, Novaliches, Quezon City when appellant allegedly stabbed him with a long double-bladed weapon and forcibly deprived him of his bicycle.
    • The assault was witnessed by Roberto Sit-Jar, who positively identified appellant in court as the assailant.
    • Florendo arrived home bleeding, was attended to by his siblings including Renato, and stated to Renato that appellant had stabbed him.
  • Medical treatment, death and expenses
    • The family took Florendo to Tordesillas Hospital then transferred him to Quezon City General Hospital due to unavailability of blood.
    • Florendo died on October 26, 1998 after treatment.
    • The family incurred hospitalization expenses of P2,896.00 and funeral expenses of P25,000.00 as shown by receipts.
  • Autopsy and cause of death
    • Autopsy by Medico-Legal Officer Dr. Dominic L. Aguda recorded: cyanosis, pale brain and visceral organs, small amount of dark clotted blood in heart chambers.
    • Findings included a sutured healing stab wound 3.0 cms on the left chest located 15.0 cms from the anterior median line directed backwards and medially passing between the 6th and 7th left ribs, entering the thoracic cavity and severing the lower lobe of the left lung to a depth of 7–8 cms.
    • Thoracostomy incisions were sutured on both chests and there was a left hemothorax of 500 cc.
    • Cause of death was recorded as stab wound, left chest.
  • Appellant’s defense
    • Appellant denied stabbing Florendo and asserted an alibi that he was working as a farm administrator for the town mayor in Urbiztondo, Pangasinan and had been living there since 1997, never visiting Manila during 1997–1998.
    • On cross-examination appellant stated that he was arrested in front of his house in Novaliches, Quezon City.
  • Trial court decision and sentence
    • On May 29, 2006, the Regional Trial Court, Branch 86, Quezon City convicted appellant of murder under Article 248 of the Revised Penal Code and sentenced h...(Subscriber-Only)

Issues:

  • Sufficiency of identification and evidence
    • Whether the prosecution proved appellant’s guilt beyond reasonable doubt through positive eyewitness identification and other evidence.
  • Credibility of eyewitness and effect of alibi
    • Whether witness Roberto Sit-Jar’s identification was credible and whether appellant’s denial and alibi sufficed to negate that identification.
  • Admissibility and weight of the victim’s statement
    • Whether Florendo’s statement to his brother Renato constituted a valid dying declaration under Rule 130, Section 37 of the Rules of Court and whether it strengthened the prosecution’s case.
  • Existence of qualifying circumstance of treachery
    • Whether the elements of treachery were present to elevate the killing to murder.
  • Penalty and damages
    • Whether the penalty of reclusion perpetua was proper under Article 248 of the Revised Penal Code, as amended by Repub...(Subscriber-Only)

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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