Case Digest (G.R. No. L-30146)
Facts:
The People of the Philippines v. Joseph Casey alias “Buri” and Ricardo Felix alias “Carding Tuwad”, G.R. No. L-30146, February 24, 1981, Supreme Court En Banc, Guerrero, J., writing for the Court. The case is an automatic review of the conviction in the Circuit Criminal Court, Rizal, in Criminal Case No. CCC-VII-6, Rizal (17857), where the trial court found both appellants guilty of murder under Article 248, Revised Penal Code, and imposed the death penalty.The prosecution filed an Information on May 22, 1968, charging Joseph Casey with murder for the March 31, 1968 killing of Alfredo Valdez in San Juan, Rizal. Casey was arraigned June 24, 1968 and pleaded not guilty. After the arrest of Ricardo Felix in September 1968, the fiscal filed an Amended Information adding Felix as a co-accused; Felix was arraigned October 15, 1968 and pleaded not guilty. The amended information repeated allegations of conspiracy, evident premeditation, treachery and taking advantage of superior strength.
At trial the prosecution presented eyewitness testimony by Mercedes Palomo, who said she saw three men exit a pool room, that Valdez was pursued by two men whom she later identified as Casey and Felix, that one (Casey) overtook and stabbed Valdez repeatedly while the other (Felix) stood nearby with a gun and fired once. Police witnesses testified to having obtained an extrajudicial statement from Casey recounting a rendezvous in Cubao and the subsequent events in Barrio Halo-Halo, San Juan, and to having found Valdez mortally wounded. The medical testimony (Necropsy Report No. 58-425) described multiple penetrating stab wounds to abdomen and back and hemorrhage as cause of death.
The defense consisted principally of the accuseds’ own testimonies. Casey admitted stabbing Valdez but claimed he acted in self-defense after Valdez allegedly lunged with a balisong; Casey said he disarmed Valdez and then stabbed him while others attacked Casey. Felix testified he did not see Casey that day, that he last saw Valdez in a store before Valdez left for Manila, and later learned of Valdez’s death. The trial court convicted both appellants of murder and sentenced them to death, with accessory penalties and indemnity of P12,000 to the heirs.
On automatic review, counsel for the accused raised seven assignments of error, contesting (inter alia) the lack of arraignment on the Amended Information, the trial cou...(Subscriber-Only)
Issues:
- Did the lack of arraignment on the Amended Information violate Casey’s constitutional right to be informed of the charge against him?
- Were evident premeditation and taking advantage of superior strength proven so as to qualify the killing as murder?
- Was there a conspiracy between Casey and Felix making Felix criminally liable as a co-principal?
- Was Casey’s plea of self-defense established by clear and convincing evidence?
- Was Felix’s alibi clearly established so as to exculpate him?
- In view of the foregoing, what is...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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