Case Summary (G.R. No. 189949)
Trial Court's Findings
The RTC concluded that the accused-appellants conspired and acted with premeditation and abuse of superior strength in the unlawful killing of Edgardo Hernandez. Evidence presented included eyewitness testimonies from three witnesses who observed the events leading to Hernandez's death, which was caused by strangulation and asphyxiation. The prosecution’s evidence indicated that the attack was carried out after the victim was confronted by the three accused, with the involvement of T/Sgt. Wilfredo Bala, who was later dropped from the case due to the lack of a presidential waiver for military jurisdiction.
Eyewitness Testimonies
The prosecution's case relied heavily on the testimonies of Zacarias Hernandez, Rosalinda Reyes, and Feliciana Napao, who provided clear accounts of the attack. Zacarias described how he encountered the accused before the shooting and witnessed the aggression towards the victim. Rosalinda testified witnessing Vicente Antonino strangling Edgardo while Manuel and Romeo kicked and boxed him, while Feliciana corroborated these actions, asserting that all three accused were involved in the assault.
Defense Claims
Vicente Antonio claimed that he acted in self-defense during the altercation. He argued that he was attacked first and used a shovel in his defense. Manuel Antonio presented an alibi, stating he was at home during the incident. Both defenses failed to convince the court, with the appellate court affirming the trial court's findings due to corroborated eyewitness accounts that directly implicated the accused.
Analysis of Conspiracy and Self-Defense
The court ruled that the evidence demonstrated a conspiracy among the accused as their actions collectively illustrated a shared intent to kill. Vicente's claim of self-defense was dismissed as there was no evidence of unlawful aggression by the victim at the onset of the confrontation. The trial court emphasized that the actions of the accused showed a common design to commit murder, negating individual defenses based on a lack of immediate and direct aggression from the victim.
Appellants' Arguments on the Trial Court's Decision
Vicente and Manuel Antonio appealed the conviction, raising various arguments, including the credibility of witnesses and the trial court's alleged errors in their interpretations. They contended that the prosecution failed to establish conspiracy convincingly and requested reconsiderat
...continue readingCase Syllabus (G.R. No. 189949)
Case Overview
- This case is an appeal from the Regional Trial Court of Nueva Vizcaya, Branch 30, where Vicente Antonio and Manuel Antonio, along with Romeo Antonio, were found guilty of murder related to the death of Edgardo F. Hernandez on December 26, 1989.
- The court sentenced Vicente and Manuel Antonio to reclusion perpetua and required them to pay damages to Hernandez's heirs. Romeo Antonio escaped before sentencing and remains at large.
Facts of the Case
- The incident occurred at approximately 8:00 PM on December 26, 1989, in Sitio Alindayo, Almaguer North, Bambang, Nueva Vizcaya, Philippines.
- The information alleged that the accused acted in conspiracy and with evident premeditation, attacking Hernandez and inflicting mortal wounds, resulting in his death.
- The commission of the crime was qualified by the aggravating circumstance of "nighttime."
- T/Sgt. Wilfredo Bala, initially included as an accused, was dropped from the case due to the absence of a Presidential waiver of military jurisdiction.
Prosecution Witnesses
- Zacarias Hernandez: Witnessed the encounter and testified seeing T/Sgt. Bala brandishing a rifle while the accused assaulted Edgardo. He was pelted with stones during the incident.
- Rosalinda Reyes: Present at the scene; observed the accused taking turns boxing and kicking Hernandez while Vicente strangled him. She heard Hernandez pleading not to