Case Summary (G.R. No. 75369)
Charges and Initial Proceedings
Aleta and Encarnacion were convicted of murder by the Court of First Instance of Quirino, which sentenced both to reclusion perpetua and to indemnify Tottoc's heirs with P55,000 in damages. Encarnacion later expressed a desire to withdraw his appeal to enjoy the advantages of being a convicted prisoner, despite his claims of innocence.
Evidence Presented
The prosecution's evidence indicated that the incident took place around 8-9 PM on December 13, 1971, during a card game. Tottoc, who was the hospital's disbursing officer, was shot by Aleta after Aleta had a confrontation with Tottoc regarding unpaid bets from a previous game. Eyewitnesses noted how Aleta initially disarmed Tottoc and shot him point-blank in the abdomen, and how Encarnacion later intervened by shooting Tottoc while he was on the ground.
Autopsy Details
An autopsy performed on Tottoc revealed multiple gunshot wounds, including a grave abdominal injury leading to internal hemorrhage, which was determined to be the cause of death. This forensic evidence corroborated eyewitness accounts of the events during the shooting.
Defense Claims
The defendants offered various defenses, arguing a lack of intent to kill and questioning the credibility of prosecution witnesses. Aleta claimed that he attempted to intervene in an altercation between Tottoc and another individual. Encarnacion supported Aleta's narrative but denied any responsibility for Tottoc's death.
Court Findings
The trial court's determination that Aleta acted with treachery was based on the sudden and unexpected nature of the assault. The court emphasized that Aleta's actions involved a calculated disarmament of Tottoc followed by a lethal attack, demonstrating a clear intention to kill. The court found Aleta guilty of murder while evaluating Encarnacion’s actions as an extension of Aleta’s assault.
Conspiracy and Joint Participation
Further analysis revealed that Encarnacion and Aleta acted in concert with a common purpose. The evidence indicated that Encarnacion's actions were not merely one of camaraderie, but part of a joint venture to kill Tottoc, as he had physically participated in the shooting after Aleta disarmed Tottoc.
Sentencing and M
...continue readingCase Syllabus (G.R. No. 75369)
Overview of the Case
- The case involves the appeal of Carlos Aleta and Benjamin Encarnacion from a conviction of murder by the Court of First Instance of Quirino.
- Both defendants were sentenced to reclusion perpetua and ordered to pay damages to the family of the victim, Zacarias N. Tottoc.
- The appeal was influenced by Encarnacion's desire to withdraw his appeal, motivated by his conditions as a convicted prisoner.
Background and Incident Description
- The events occurred on December 13, 1971, at the Northeastern Nueva Vizcaya Emergency Hospital during a card game involving several employees.
- Zacarias N. Tottoc was present, having recently been audited by Eudocia C. Ambatali, when Aleta, who had been drinking, offered to play cards.
- Aleta lost several games and did not pay the winners, leading to Tottoc's sarcastic remarks about the betting practices.
- These remarks provoked Aleta, who subsequently shot Tottoc after disarming him.
Sequence of Events Leading to the Shooting
- Aleta approached Tottoc, inquiring if he was angry, and shot him pointblank in the abdomen.
- A struggle ensued for the gun, during which Encarnacion intervened and shot Tottoc twice while he was on the floor.
- Aleta, Encarnacion, and their companions fled the scene in a jeep.
Witness Testimonies
- Multiple witnesses,