Case Summary (G.R. No. 236166)
Applicable Law
The relevant legal framework governing this case is the 1987 Philippine Constitution, as the decision was rendered after 1990, alongside provisions in the Revised Penal Code concerning homicide and justifying circumstances such as self-defense.
Background of the Incident
On the night in question, Kenneth and Jet Lee were engaged in a drinking spree at their residence with family and friends. An argument ensued between the couple, which escalated to Jet Lee screaming for help after she had been stabbed. Witnesses provided testimony supporting the prosecution's arguments regarding a history of jealousy and prior altercations between the couple.
Evidence Presented
Key testimonies included that of Cleopatra Reyes, the victim's mother, who described witnessing the aftermath of the stabbing and Jet Lee's distressed state while blaming Aspiras for the attack. Friends of both the victim and the accused testified to Aspiras' jealous and violent tendencies based on previous encounters, indicating a pattern of abuse that could have led to the incident.
Trial Court Proceedings
The RTC found Aspiras guilty of homicide, concluding that he had committed the act of stabbing Jet Lee beyond reasonable doubt while rejecting claims of self-defense. The court noted a lack of evident premeditation, treachery, and abuse of superior strength that would elevate the charge to murder. It determined that Aspiras' narrative was inconsistent and lacked credible support.
Court of Appeals Decision
Upon appeal, the Court of Appeals upheld the RTC's conviction while remedying certain aspects of the damages awarded to the victim's heirs. It found that the RTC had properly examined the evidence and established Aspiras' guilt for homicide but also adjusted the civil aspects of the ruling, awarding additional exemplary damages.
Legal Objections Raised
Aspiras contested the validity of the information leading to his indictment, claiming it lacked the proper approval from the City Prosecutor, as mandated by Rule 112, Section 4 of the Rules of Court. However, the Court of Appeals refuted this argument, citing that certain procedural requirements had been met, including the certification of the Assistant City Prosecutor and the presumption of regularity in the filing.
Self-Defense Claim
Aspiras argued that he acted in self-defense, insisting that Jet Lee attacked him first with a knife. However, both lower courts found his self-defense claim unconvin
...continue readingCase Syllabus (G.R. No. 236166)
Background and Charges
- Petitioner Kenneth Karl Aspiras y Corpuz (Aspiras) was charged with Murder under an Information dated January 13, 2011, in Manila, Philippines.
- The charge was based on allegations that Aspiras, with intent to kill and employing treachery, premeditation, and superior strength, stabbed the victim, Jet Lee Reyes y Daquil, resulting in her death.
- A preliminary investigation and a resolution affirmed probable cause for the charge of murder.
- Aspiras pleaded not guilty and was released on bail.
Facts Established During Trial
- Aspiras and Jet Lee were common-law spouses living in a shared family home in Tondo, Manila.
- On the date of the incident, a drinking session occurred involving Aspiras, Jet Lee, and others from 6:00 p.m. to about 10:00 p.m.
- Neighbors and family members testified about frequent quarrels and incidents of jealousy and violence initiated by Aspiras towards Jet Lee.
- Cleopatra Reyes, mother of the victim, heard a quarrel and then screams; she saw Aspiras with bloodied hands and Jet Lee wounded.
- Evidence showed Jet Lee sustained two stab wounds and hematoma on the eye, with a fatal abdominal wound.
- Aspiras claimed self-defense, alleging that Jet Lee attacked him first with a knife.
Trial Court Findings and Judgment
- The Regional Trial Court found Aspiras guilty of homicide, not murder, due to lack of evident premeditation, treachery, or abuse of superior strength.
- The court rejected Aspiras' claim of self-defense as insufficiently substantiated.
- The Court found Aspiras’ version of events to be inconsistent and unconvincing, noting lack of legitimate justification for stabbing Jet Lee.
- Aspiras was sentenced to an indeterminate penalty of seven to fourteen years imprisonment.
- Civil indemnity, moral damages, and interest were awarded to the victim's heirs.
Court of Appeals Decision
- The Court of Appeals affirmed with modification the Regional Trial Court’s decision.
- It ruled that the Information was valid despite questions on the approval signature, citing certification and prior aut