Case Summary (G.R. No. 94702)
Background of the Case
On November 22, 1988, Tranquilino Mariano was killed by Ramos, Dionisio, and Carlito Acuna. The accused were charged with murder, with the information enumerating the circumstances surrounding the crime, including evident premeditation, abuse of superior strength, and treachery. Following their arrest on April 17, 1989, Ramos and Dionisio pleaded not guilty during their arraignment on June 28, 1989.
Evidence Presented
Witnesses testified that on the night of the murder, Ramos, Acuna, and Dionisio confronted Mariano outside Ramos's house. Eyewitnesses observed Acuna attacking Mariano with a piece of wood while the other two restrained him. The prosecution's case was bolstered by the testimonies of Victoria Magana and Luisa Blanco, who witnessed the assault. An autopsy conducted by Dr. Juanito B. Sacdalan revealed that Mariano sustained multiple stab wounds and had a hematoma on his left eye, corroborating the eyewitness accounts of violent physical assault.
Defense and Credibility of Witnesses
The defense relied on a strategy of simple denial, emphasizing inconsistencies in eyewitness statements to create reasonable doubt. However, the appellate court upheld the trial court's assessment of witness credibility, reaffirming that inconsistencies in minor details may actually enhance a witness's credibility rather than diminish it. The testimonies remained consistent on essential facts, providing a coherent narrative of the events leading to the murder.
Considerations of Appeal
The appellate court reviewed the challenges posed by the appellants regarding the reliability of eyewitness accounts. The defense argued the improbability of not detecting the witnesses during the crime, yet the court noted that the perpetrators' intoxication likely contributed to their distraction. The relationships between the eyewitnesses and the victim were deemed irrelevant to their credibility, and a lack of ill motive further strengthened their testimonies.
Legal Findings
The trial court's conclusions regarding the nature of the crime were upheld. The appellate court affirmed that the killing qualified as murder under Article 248 of the Revised Penal Code, detailing that abuse of superior strength was evident owing to the trio's overwhelming force against Mariano. The court noted the absence of treachery and evident premeditation, as these elements were not sufficiently substantiated by the evidence.
Sentencing and C
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Case Overview
- Case Number: G.R. No. 94702
- Date of Decision: October 02, 1995
- Parties Involved:
- Plaintiff-Appellee: People of the Philippines
- Defendants: Carlito Acuna, Jesus Ramos, and Antonio (Tony) Dionisio
- Defendant-Appellants: Jesus Ramos and Antonio (Tony) Dionisio
- Trial Court: Regional Trial Court of Malolos, Bulacan, Branch 20
- Original Decision Date: May 22, 1990
- Crime Charged: Murder of Tranquilino Mariano
Facts of the Case
- Incident Date: November 22, 1988
- Location: Municipality of Calumpit, Province of Bulacan, Philippines
- Circumstances:
- Acuna, Ramos, and Dionisio attempted to persuade Tranquilino Mariano to join them on two occasions.
- Following Mariano's refusal, the trio returned and, with permission from Mariano's wife, took him from his home.
- Witnesses, Victoria Magana and Luisa Blanco, observed an altercation between the accused and Mariano where Acuna struck Mariano with a piece of wood.
- The three assailants then stabbed Mariano multiple times after he fell.
- Mariano's body was discovered the following morning by a passerby, leading to an autopsy confirming multiple stab wounds and blunt force trauma.
Procedural History
- Arrest: Ramos and Dionisio were arrested on April 17, 1989; Acuna remains at large.
- Bail Motion: An urgent motion for bail was filed but was denied on June 1, 1989.
- Arraignment: Both defendants pleaded not guilty on June 28, 1989.
- Trial: Evidence presented during preliminary hearings was carried over to the trial.
Evidence Presented
Prosecution Witnesses:
- Eyewitnesses Victoria Magana and Luisa Blanco testified to witnessing