Case Digest (G.R. No. 87202)
Facts:
People of the Philippines v. Rafael Velaga, Jr., G.R. No. 87202, July 23, 1991, Supreme Court Second Division, Paras, J., writing for the Court.The prosecution charged Rafael Velaga, Jr. (accused-appellant) with murder before the Regional Trial Court (RTC) of Dagupan City for the stabbing death of Virgilio dela Cruz on December 16, 1980. The information was filed March 31, 1981; upon arraignment on October 4, 1985 the accused pleaded not guilty. The record shows that after an alleged collision between the accused’s motorcycle and a Toyota Land Cruiser, a heated argument ensued; while the victim stood between the combatants to pacify them, the prosecution’s witnesses testified that the accused suddenly drew a knife and stabbed the victim, who later died in hospital three days after the incident.
At trial the prosecution presented eyewitness testimony describing the collision, the ensuing argument, the victim’s attempt to pacify the parties, and the immediate stabbing. The defense presented a contrary version: the accused testified he acted in legitimate self-defense, claiming that one of the deceased’s companions struck him and that a struggle for a knife ensued during which the knife fatally wounded the victim. The case was archived initially because the accused was at large; he was arrested in September 1985 and tried thereafter.
The RTC convicted the accused of murder and sentenced him to reclusion perpetua, finding the generic aggravating circumstance of nighttime present and ordering indemnity to the heirs. The accused appealed to this Court, assigning (1) erroneous rejection of his plea of self-defense, (2) erroneous appreciation of treachery as...(Subscriber-Only)
Issues:
- Was the accused’s plea of self-defense properly rejected by the trial court?
- Was treachery established so as to qualify the killing as murder?
- Was nighttime properly appreciated as an aggravating ...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)