Case Digest (G.R. No. 126145)
Facts:
People of the Philippines v. Hermes B. Sarmiento, Rudy Sarmiento, and Lolita B. Sarmiento, G.R. No. 126145, April 30, 2001, the Supreme Court First Division, Puno, J., writing for the Court. The respondents at trial were spouses Hermes B. Sarmiento and Lolita B. Sarmiento and their son Rudy Sarmiento; Hermes and Rudy prosecuted the appeal as accused‑appellants.The three were charged in the Regional Trial Court (RTC) of Virac, Catanduanes with murder for the April 27, 1993 killing of Nilo Tablizo. The Information alleged that the accused, with treachery and evident premeditation and by abusing superior strength, conspired and stabbed the victim, causing instantaneous death. At arraignment the accused pleaded not guilty and trial ensued.
The prosecution presented eyewitnesses—Lorenzo Eustaquio, Rodel Tablizo (the victim’s brother), and John Aldave—who testified that Hermes seized the victim’s collar and stabbed him, then told Rudy to stab as well; the two took turns stabbing the victim, who later collapsed and died. A medico‑legal certificate by Dr. Ma. Theresa Mariano recorded multiple stab wounds (twelve in all) and hemorrhagic shock as cause of death; two chest wounds were fatal. The prosecution also offered testimony about an earlier dispute over a missing carabao allegedly found with the Sarmientos; Hermes had allegedly threatened retaliation.
The defense presented an account that the Sarmientos had been coming from a fiesta and were on foot when an altercation erupted: the victim had allegedly boxed Hermes and later struck Rudy, prompting Rudy to stab in purported defense of his father and himself. Defense witnesses (Allan Alpon, Felipe Fernandez, Jr.) recounted some jostling and that Rudy stabbed the victim; other witnesses contradicted certain defense details. The defense argued self‑defense and defense of a relative for Rudy, and denied Hermes’s active participation or that Lolita supplied the weapon.
On December 1, 1995 the RTC convicted Hermes and Rudy for murder and acquitted Lolita for reasonable doubt; it sentenced Hermes and Rudy to reclusion perpetua and ordered indemnity to the heirs. Hermes and Rudy appealed raising three assignments (challenging the credibility findings of eyewitnesses, asserting insufficiency of proof beyond reasonable doubt, and claiming justification by self‑defense/defense of a relative). The matter was brought to the Supreme Court by the present appeal.
The Supreme Court (First Division) reviewed the record, upheld the RTC’s credibility de...(Subscriber-Only)
Issues:
- Did the trial court err in finding the prosecution eyewitnesses credible and in accord such that their testimony established the appellants’ guilt beyond reasonable doubt?
- Was the killing by accused‑appellant Rudy Sarmiento justified by self‑defense or defense of a relative?
- Are the aggravating circumstances of treachery, evident premeditation, and abuse of superior strength present, and what are the pro...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)