Case Digest (G.R. No. 256468)
Facts:
The case is People of the Philippines v. Arvi Villa y Garcia, G.R. No. 256468, October 11, 2023, Supreme Court Third Division, Inting, J., writing for the Court. The plaintiff-appellee is the People of the Philippines; the accused-appellant is Arvi Villa y Garcia.In three separate Informations, accused-appellant was charged with two counts of Murder (Crim. Case Nos. 14-307999 and 14-308000) and one count of Frustrated Murder (Crim. Case No. 14-308001), all allegedly committed on August 1, 2014 in Sta. Ana, Manila. The Informations alleged that accused-appellant shot Maria Lourdes Tolentino Aguilar and Sergio Aguilar, Jr., causing their deaths, and shot his live-in partner Maridref Tolentino y Rico, inflicting multiple gunshot wounds. Accused-appellant pleaded not guilty and trial on the merits followed.
The prosecution presented eyewitness testimony (Maridref, PO2 Ruel Villaranda, Lemuel Vallenas), ballistic and forensic examinations (Manila Police firearms and crime-laboratory officers), and medico-legal reports establishing fatal head wounds for Maria Lourdes and Sergio and multiple non-specified gunshot wounds for Maridref. Witness Vallenas testified to hearing multiple shots and seeing the assailant (identified in court as accused-appellant) point a gun at his own head and shoot himself. Maridref testified about the breakup of her seven-year relationship with accused-appellant, his bringing a gun to her mother’s house that night, seeing him through a mirror, and the subsequent shooting; she survived and received medical treatment. Accused-appellant testified that he had little recollection of the events, claiming loss of consciousness and that, as told by his parents, he had attempted suicide.
The Regional Trial Court (RTC), Branch 16, Manila, in a Consolidated Decision dated August 29, 2018, convicted accused-appellant of two counts of Murder and one count of Frustrated Murder, finding treachery and evident premeditation and sentencing him to reclusion perpetua without eligibility for parole for each murder count and imposing penalties and damages (including awards for burial expenses, loss of earning capacity, moral and exemplary damages). Accused-appellant appealed to the Court of Appeals (CA).
In a Decision dated September 30, 2020, the CA in CA-G.R. CR-HC No. 11793 affirmed the RTC judgment but modified the damages in the frustrated-murder case, awarding P75,000.00 each for moral and exemplary damages to Maridref. The CA rejected accused-appellant’...(Subscriber-Only)
Issues:
- Whether the Court of Appeals erred in upholding the conviction when it did not appreciate the exempting circumstance of insanity.
- Whether the elements of Murder (including treachery and evident premeditation) were proven beyond reasonable doubt.
- Whether the wounds sustained by Maridref constituted Frustrated Murder or, instead, only Attempted Murder, and the app...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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