Case Digest (G.R. No. 124666)
Facts:
People of the Philippines v. Renato Samson y Corea, G.R. No. 124666, February 15, 2002, the Supreme Court En Banc, Sandoval‑Gutierrez, J., writing for the Court.The prosecution (plaintiff‑appellee) charged Renato C. Samson (accused‑appellant), then a barangay tanod of La Huerta, Parañaque, with murder for the shooting death of Sol Homicillada on or about August 28, 1994. The Information alleged that Samson, with treachery and evident premeditation, shot and killed the victim. At arraignment on November 24, 1994, the accused pleaded not guilty.
At trial the prosecution presented five witnesses, the principal of whom was eyewitness John Dexter Tuazon Daylag. John testified that on the night of August 27–28, 1994 he and Sol were playing darts when two armed men suddenly arrived and fired two shots. Sol tried to flee and bumped into John; one assailant pointed his gun at Sol while the other shot Sol in the left back, causing him to fall. The assailant who passed by John then approached Sol and, at close range, fired three to four additional shots at Sol’s head. John identified that assailant as the accused, describing his clothing (white T‑shirt, green shorts, blue scarf) and saying the scarf was blown off so he saw the face; the accused’s companion was identified as Marcelo Aniag. John later gave a sworn statement at Camp Ricardo Papa.
Police arrested the accused on August 31, 1994; three .38 live ammunitions were seized. Dr. Antonio Vertido (NBI Medico‑Legal Officer) performed autopsy and found six gunshot wounds on the victim, one wound showing close‑range smudging; Ireneo Ordeano (NBI ballistician) testified that the recovered slugs were from a .38 caliber firearm. Samson denied the charge, disclaimed knowledge of the victim and Aniag, and suggested John bore a grudge from a prior quarrel (April 1994). A neighbor, James Odialles, disputed particulars of John’s account.
The Regional Trial Court, Branch 258, Parañaque City, in Criminal Case No. 94‑0720, on February 27, 1996 convicted Samson of murder qualified by treachery and se...(Subscriber-Only)
Issues:
- Did the trial court err in relying mainly on the testimony of the prosecution eyewitness John Dexter Tuazon Daylag despite alleged inconsistencies in his testimony?
- Was the killing properly qualified as murder by treachery, and, if so, was the imposition of the death penalty appropriate under Article 248 of the Revised Penal Code a...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)