Case Summary (G.R. No. 254747)
Applicable Law
This case is governed by the provisions of the Revised Penal Code, specifically Article 248, which outlines the elements and penalties for murder.
Antecedents
The accused-appellant, along with co-accused Ronnel Dela Vega and others, was charged with murder under Article 248 of the Revised Penal Code. The Information alleged that they conspired to unlawfully attack the victim, Joey Puro Toong, resulting in serious bodily harm and ultimately, his death. During the arraignment, the accused-appellant and Ronnel Dela Vega entered not-guilty pleas, while other co-accused remained at large.
Prosecution's Case
The prosecution presented several witnesses, including the victim's mother, Anacleta Toong, the victim's friend, Philip Baltes, and Police Officer 3 Modestino G. Juanson, who recounted the events of the attack. On the night in question, Baltes witnessed a group of seven to eight male teenagers assaulting the victim. He noted that after the victim was attacked and stabbed by the accused-appellant, the group continued to assault him until he became incapacitated. Subsequently, Baltes and the victim's brother transported the victim to a hospital where he succumbed to his injuries.
Defense's Case
The accused-appellant denied involvement in the crime, asserting he was in Tarlac City at the time of the incident. He claimed to have presented a barangay certification to support this alibi, as well as testimonies from co-accused Ronnel, who similarly professed innocence. Notably, on March 29, 2016, Baltes recanted his earlier testimony, stating he did not see the accused on the night of the incident.
Regional Trial Court (RTC) Ruling
In its decision dated September 15, 2017, the RTC found the accused-appellant guilty beyond reasonable doubt of murder, taking into account the eyewitness testimony from Baltes. The RTC emphasized that Baltes' recantation seven years after the fact merited scant consideration, and ruled that all elements of the crime were proven. Ronnel was acquitted for lack of evidence linking him to the murder.
Court of Appeals (CA) Ruling
The CA upheld the RTC's ruling on February 10, 2020, affirming the conviction and sentence of the accused-appellant. The CA dismissed the allegations of prejudice due to the recantation and reiterated the reliability of Baltes' initial testimony.
Issues for Consideration
- Is the CA's affirmation of the RTC's decision erroneous due to the recantation of the key eyewitness?
- Did the CA err in validating the identification of the accused-appellant as one of the perpetrators?
- Should the defenses of denial and alibi presented by the accused-appellant have been given more weight?
Ruling
The Court found the appeal unmeritorious and affirmed the findings of the RTC and CA. The Court reiterated that th
...continue readingCase Syllabus (G.R. No. 254747)
Case Overview
- The case involves an appeal by Rod Angeles y Manlapaz, also known as "Uro," challenging the Decision of the Court of Appeals (CA) which affirmed his conviction for Murder under Article 248 of the Revised Penal Code (RPC).
- The appeal was initiated against the backdrop of a guilty verdict rendered by the Regional Trial Court (RTC), Quezon City, which found the accused-appellant guilty beyond reasonable doubt.
Antecedents
- The Information filed accused Rod Angeles and co-accused Ronnel Dela Vega, Marjune Lalikan, Reymark Angeles, and Jomar Mediola of Murder committed against Joey Puro Toong.
- The incident occurred on July 15, 2009, in Quezon City, where the accused allegedly conspired to kill the victim using superior strength.
- The prosecution claimed that the accused attacked, mauled, and stabbed the victim, inflicting serious and mortal wounds leading to his death.
Prosecution's Version
- The prosecution's primary witnesses included the victim's mother, Anacleta Toong, the victim's friend, Philip Baltes, and Police Officer 3 Modestino G. Juanson.
- Philip Baltes testified he witnessed a group of 7 to 8 male teenagers attack the victim near a bakery. He recognized some attackers as schoolmates.
- Baltes described seeing the victim being mauled, stabbed by accused-appellant with a double-edged knife, and subsequently impaled by another assailant using an ice pick.
- Baltes attempted to assist but was prevented by the chaotic scene, and after the assailants fl