Case Digest (G.R. No. 175602)
Facts:
People of the Philippines v. PO2 Eduardo Valdez and Edwin Valdez, G.R. No. 175602, February 13, 2013, the Supreme Court Special First Division, Bersamin, J., writing for the Court.The accused, PO2 Eduardo Valdez and Edwin Valdez, were tried before the Regional Trial Court (RTC), Branch 86, Quezon City, for three counts of murder. On January 20, 2005 the RTC convicted both accused as charged and imposed reclusion perpetua for each count, and ordered payment of P93,000 as actual damages, P50,000 as civil indemnity, and P50,000 as moral damages to the heirs of each victim.
On July 18, 2006 the Court of Appeals (CA) affirmed the RTC’s convictions but modified the civil awards: it ordered each accused to pay, per victim, P50,000 as civil indemnity, P50,000 as moral damages, P25,000 as temperate damages, and P25,000 as exemplary damages, plus costs. Both accused sought relief in the Supreme Court by way of final appeal, but on May 9, 2007 Edwin filed a motion to withdraw his appeal, which the Court granted on October 10, 2007, thereby terminating Edwin’s appeal.
The Supreme Court thereafter resolved the appeal of PO2 Eduardo Valdez and, by a judgment promulgated January 18, 2012, modified the CA decision by finding Eduardo guilty only of three counts of homicide (not murder) and sentencing him to the indeterminate term of 10 years of prision mayor as minimum to 17 years of reclusion temporal as maximum for each count, and ordering reduced civil damages per victim. The January 18, 2012 judgment rested on (a) the forensic and eyewitness evidence establishing the shootings, (b) the conspiracy between the accused, and (c) the insufficiency of the informations to allege treachery as an attendant circumstance.
On March 12, 2012 Edwin sent a letter to the Court Administrator asking that the favorable January 18, 2012 judgment rendered on Eduardo’s appeal be applied to him under Section 11(a), Rule 122 of the Rules of Court, arguing that the reduced liability would be beneficial. The Solicitor General filed a comment on September 25, 2012 expressing no opposition. The Court, in the present Resolution dated...(Pro-only)
Issues:
- Does Section 11(a), Rule 122 of the Rules of Court permit Edwin Valdez—who withdrew his appeal and whose conviction became final—to benefit from the Supreme Court’s favorable modification of his co-accused Eduardo’s conviction?
- Was it proper for the Supreme Court to modify Eduardo Valdez’s conviction from murder to homicide on the ground that the informations failed to...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)