Title
People vs. Villanueva y Andes
Case
G.R. No. 107495
Decision Date
Jul 31, 1995
Jose Villanueva was found guilty of murder with treachery and dwelling as aggravating circumstances, sentenced to reclusion perpetua, supported by credible eyewitness testimony and physical evidence.
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Case Digest (G.R. No. 107495)

Facts:

  • The case involves People of the Philippines vs. Jose Villanueva y Andes, G.R. No. 107495, decided on July 31, 1995.
  • Jose Villanueva y Andes and his brother-in-law, Carlo Uycoque, were charged with murder on May 6, 1991.
  • Both accused pleaded "not guilty" during their arraignment on August 2, 1991.
  • The incident occurred on May 2, 1991, around 9:30 PM, when the victim, Lucas Flores, was at home with his wife, Francisca.
  • Lucas was forcibly taken outside by an assailant with a gun after he opened the door.
  • Francisca heard gunshots and found Lucas shot multiple times; he later died from seven gunshot wounds.
  • Jose Villanueva surrendered, claiming self-defense, alleging Lucas threatened him with a grenade.
  • The trial court convicted Villanueva of murder and acquitted Uycoque due to insufficient evidence.
  • Villanueva was sentenced to reclusion perpetua and ordered to pay damages to the victim's heirs.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court affirmed the lower court's finding of treachery in the killing of Lucas Flores.
  • The Court ruled that the lower court did not err in rejecting the self-defense claim of the accused.
  • The Court upheld the finding of the aggravating circumstance of dwelling.
  • The Court confirmed the imposition of reclusion perpe...(Unlock)

Ratio:

  • The Supreme Court emphasized the trial court's credibility assessments of witnesses, as it is better positioned to evaluate their demeanor.
  • Francisca Flores's testimony was credible, as she witnessed the sudden and unexpected attack, qualifying the crime as murder with treachery.
  • Physical evidence contradicted Vil...continue reading

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