Case Digest (G.R. No. L-4116)
Facts:
People of the Philippines v. Epifanio O. Valerio, Jr., and Domingo Elepano, G.R. No. L-41146, February 25, 1982, the Supreme Court En Banc, Melencio-Herrera, J., writing for the Court.The respondents are Epifanio O. Valerio, Jr. (accused) and Domingo Elepano (accused); co-accused Amador Castro pleaded guilty and was separately sentenced. The criminal information in Cavite charged them with Murder for the drowning and head injury death of an eight-year-old boy who had been insured in a scheme to collect insurance proceeds.
Chronology and lower-court proceedings: In November 1972 an insurance policy for P20,000.00 was taken out on a boy presented as “Amador Castro, Jr.” Testimony and documentary evidence established that Valerio, an insurance sub-agent, proposed the insurance-for-murder scheme, drafted the application, assisted in baptismal and insurance formalities, and contributed premiums; Castro and others participated. When the originally insured child disappeared, Valerio allegedly supplied a substitute boy. On March 13, 1973, at Lido Beach, Cavite, the substitute boy was struck on the head and submerged; the autopsy showed traumatic meningeal hemorrhage and death by submersion. Fingerprint comparison, however, showed the dead boy was not the insured child, and the insurance claim was denied.
The Provincial Fiscal filed an Information on June 26, 1973. At arraignment Castro pleaded guilty and was sentenced to prision mayor (minimum) to reclusion temporal (maximum). Valerio pleaded not guilty and raised an alibi (medical confinement from March 12–14, 1973). Elepano was subsequently included in an amended Information (April 24, 1974); the trial court conducted separate trials and, on July 31, 1975, convicted both Valerio and Elepano of Murder and imposed the death penalty on each, plus civil indemnity and moral/exemplary damages. Castro’s extrajudicial statements to NBI agents (April 1973) implicated both Valerio and Elepano; in court Castro consistently implicated Valerio but repudiated portions of his statement that inculpated Elepano.
Because of the death sentences, the case came to the Supreme Court on automatic review. The Court received trial records, witness testimony (i...(Subscriber-Only)
Issues:
- Did the trial court err in crediting the prosecution evidence and disbelieving the alibi of Valerio and Elepano such that their convictions should be overturned?
- Did the trial court err in imposing the death penalty on Valerio without expressly finding the qualifying and aggravating circumstances alleged in the Information?
- Was there sufficient evidence to convict Elepano beyond reasonable doubt of conspiracy and murder?
- Was the award of civil indemnity and moral/exemplary damages to the heirs ...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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