Case Summary (G.R. No. 167333)
Factual Background
The RTC charged the petitioner and Herman Licup with homicide for an attack on Erwin de Ramon, resulting in his death. Witnesses described how the petitioner unexpectedly stabbed the victim with a machete during a public gathering. The victim sustained fatal wounds and died shortly thereafter. Medical testimony confirmed the nature of the injuries, indicating they were caused by sharp objects.
Defense Strategy
In defense, the petitioner provided an alibi, claiming he was with his family during the incident and had learned about the stabbing through a barangay tanod. He presented two witnesses to corroborate his presence at the dance and asserted that the prosecution witnesses bore ill will towards him due to previous conflicts.
Judgment of the RTC
On February 10, 2003, the RTC convicted the petitioner, declaring him guilty of homicide. He received an indeterminate sentence of 10 years and 1 day of prision mayor as minimum to 17 years and 4 months of reclusion temporal as maximum, alongside a civil indemnity payment of P50,000. Licup was acquitted due to insufficient evidence.
Decision of the Court of Appeals
The petitioner appealed, asserting that the trial court erred in his conviction, particularly given the injuries sustained by Licup during the altercation. The CA, however, dismissed the appeal, affirming the RTC's judgment on December 10, 2003, concluding that the evidence against the petitioner sufficiently satisfied the burden of proof.
Legal Issues Raised
The petitioner raised substantial questions regarding the CA's upholding of his conviction, claiming the emergence of new evidence that could establish reasonable doubt regarding his guilt. The State countered that appeals should be focused on legal questions rather than factual discrepancies, arguing that the proposed "newly-discovered evidence" did not meet the necessary legal standards.
Ruling of the Court
The Supreme Court found the appeal without merit, emphasizing that a petition under Rule 45 must raise only questions of law, not fact. It reiterated that the factual determinations made by the RTC and CA are binding in the absence of recognized exceptions, none of which applied in this case.
Newly-Discovered Evidence
The Court rejected the petitioner's claim regarding the res gestae statement of Licup, asserting it did not qualify as newly-discovered evidence. The process for introducing such evidence under appeal lacks precedent, and it was noted that the petitioner could have discovered the evidence during trial with reasonable diligence.
Sentence Correction
The Court determined that the imposition of the maximum penalty without proper justification by the lower courts was a legal error. Consequently, the Court modified the sentencing framework, adjusting the maximum of the indeterminate sentence to the lowest of the medium period of reclu
...continue readingCase Syllabus (G.R. No. 167333)
Case Overview
- The petitioner, Pedro Ladines, appeals a decision from the Court of Appeals (CA) affirming his conviction for homicide by the Regional Trial Court (RTC) in Sorsogon City.
- The RTC's judgment was issued on February 10, 2003, and the CA's decision was promulgated on October 22, 2004.
Factual Background
- An information was filed against Ladines and co-accused Herman Licup, charging them with homicide for the death of Erwin de Ramon on June 12, 1993.
- The incident occurred during the Grand Alumni Homecoming of the Bulabog Elementary School.
- Witnesses testified that Ladines approached and stabbed Erwin below the navel with a machete, after which Licup also attacked Erwin.
- Erwin was able to stab Licup in the chest before he was subsequently rushed to the hospital but succumbed to his injuries.
- A post-mortem examination by Dr. Myrna Listanco revealed two stab wounds, indicating that different weapons may have been used.
Defense and Trial Court Judgment
- Ladines presented an alibi, claiming he was with his family at the dance event and only learned about the stabbing incident afterward.
- He asserted that prosecution witnesses had motives to falsely accuse him due to previous disputes.
- The RTC found Ladines guilty beyond reasonable doubt of homicide, sentencing him to an indeterminate prison term and ordering him to pay civil indemnity to the victim's heirs.