Case Digest (G.R. No. 175602)
Facts:
People of the Philippines v. PO2 Eduardo Valdez and Edwin Valdez, G.R. No. 175602, January 18, 2012, Supreme Court First Division, Bersamin, J., writing for the Court.The respondents-accused, brothers Eduardo (a police officer, PO2) and Edwin Valdez, were charged by the Office of the City Prosecutor of Quezon City with three counts of murder for the deaths of Ferdinand Sayson, Moises Sayson, Jr., and Joselito Sayson allegedly committed on March 1, 2000, at a jai alai betting station/canteen in Quezon City. Each information alleged conspiracy, intent to kill, and qualifying circumstances of treachery, evident premeditation and abuse of superior strength.
The prosecution presented eyewitness testimony (including Estrella, Susan and Marites Sayson) recounting that the two accused arrived together on a motorcycle, were armed, called for a teller (Jonathan Rubio), an altercation followed when Moises intervened, and one accused fired successive shots that killed Moises and, immediately thereafter, Edwin shot Ferdinand and Joselito. Medico-legal evidence showed close-range gunshot wounds consistent with the testimony.
The accused’s theory (advanced by the Public Attorneys’ Office) was self-defense: Edwin stated he was accosted and grappled with Moises, and Eduardo claimed he was attacked and fired only in defense, that he played dead and later surrendered his service firearm to superiors. Both surrendered and were tried.
The Regional Trial Court (RTC), Branch 86, Quezon City, found both guilty of three counts of murder on January 20, 2005, imposing reclusion perpetua for each count and awarding damages to the heirs. On appeal the Court of Appeals (CA) affirmed on July 18, 2006 but modified the awards. Edwin later moved to withdraw his appeal, which was granted...(Pro-only)
Issues:
- Did the trial court and Court of Appeals err in accepting and crediting the State’s eyewitness testimony and physical evidence over the accused’s self-defense claim?
- Was there sufficient proof of conspiracy between Eduardo and Edwin Valdez?
- Did the informations sufficiently allege the qualifying circumstance of treachery so as to sustain convictions fo...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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