Case Digest (G.R. No. 131915)
Facts:
People of the Philippines v. Eddie Lachica (At-Large), Ariel Rollon, and Errol Rollon, G.R. No. 131915, September 03, 2003, Supreme Court Second Division, Callejo, Sr., J., writing for the Court.The prosecution charged Eddie Lachica, Ariel Rollon, and Errol Rollon with the murder of Alejandro Rogero occurring on the evening of September 24, 1995, in Sitio Sapang Palay, Barangay Pili, San Fernando, Romblon. The incident arose out of a melee that began at a wake; earlier skirmishes involved several persons (including Kagawad Jose Rafol and his sons) and culminated in a confrontation near the gate of Barangay Captain Royo’s house. Eyewitnesses saw a tricycle carrying Errol (the driver), Ariel, Eddie, and others approach Alejandro and Melchor Rogero; an exchange of words and blows followed, Ariel hacked Alejandro with a bolo, Eddie fired a shot, and Errol allegedly shot Alejandro twice and ran over his body with the tricycle while Ariel and others further hacked the victim.
An autopsy by Dr. Leticia V. Chan documented multiple injuries—five gunshot wounds, numerous incised wounds, abrasions and partial amputation of a thumb—and concluded cause of death was internal hemorrhage due to gunshot wounds. Melchor Rogero (the victim’s brother) and Kagawad Thomas Rios testified identifying Errol as one of the assailants, describing the sequence of blows, shots and the tricycle running over Alejandro’s body. SPO4 Ramon Rutor investigated and recovered a bolo surrendered by Ariel; Eddie Lachica remained at large during trial.
An Information charged the three with murder qualified by treachery, abuse of superior strength and cruelty under Article 248, as amended by Republic Act No. 7659. At trial Errol and Ariel pleaded not guilty; the trial court found them guilty beyond reasonable doubt, disbelieved their plea of self-defense and denials, and convicted both (sentencing to reclusion perpetua and ordering civil indemnity). Ariel later died in detention; his appeal was dismissed and only Errol’s appeal reached the Court. Errol argued the trial court erred in (1) rejecting ...(Pro-only)
Issues:
- Did the trial court commit reversible error in accrediting the prosecution witnesses and rejecting appellant Errol Rollon’s denial and plea of self-defense?
- Were the qualifying and aggravating circumstances supporting conviction for murder established (in particular, was abuse of superior strength proven and could firearm use be treated as an aggravating circumstance)?
- What is the proper penalty and the appropriate civil l...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)