Case Summary (G.R. No. 126171)
Background of the Case
Artemio Aquino, who was apprehended in December 1996 after being at large for several years, was tried for the murder of Ricardo Junio. The Regional Trial Court in Dagupan City found him guilty of murder on May 23, 1997, and sentenced him to reclusion perpetua, alongside various civil liabilities. Ernesto Aquino was previously acquitted of the charges against him.
Testimony of Witness
The prosecution's case relied heavily on the testimony of witness Eduardo Barte, who reported witnessing Artemio stab Ricardo. According to Barte, the attack occurred after Artemio approached Ricardo for a conversation. The stabbing was characterized as sudden and left Ricardo with no opportunity to defend himself, leading to acute injuries resulting in his death shortly thereafter.
Accused's Defense
Artemio Aquino contested the enforcement of the murder charge by asserting that he was at home caring for his children at the time of the incident. He further claimed that Barte's testimony was fabricated and did not provide a reliable account of the actual stabbing. The defense failed to present substantial evidence or compelling instances to support their allegations against the credibility of Barte's testimony.
Trial Court's Findings
The trial court considered Barte's testimony as direct, clear, and credible, leading to the conviction of Artemio on the basis of the established fact that he was identified as the assailant. The court emphasized the importance of credibility evaluations made during the trial while affirming the account displayed by Barte.
Treachery and Applicable Circumstances
During appeal, Artemio argued that treachery, a qualifying circumstance for murder, was improperly applied in his conviction. The Court underscored that for treachery to be established, it must be proven that the assailant deliberately adopted a method preventing the victim from defending himself. The Court found insufficient evidence to satisfy this criterion, noting that the attack’s initial circumstances were not adequately delineated by the prosecution.
Modification of Conviction
Upon review, the appellate court determined that treachery could not be established, prompting a reduction of Artemio's offense from murder to homicide. The court ruled that while there were elements that evidenced homicidal wrongdoing, the requisite for qualifying the act as murder was not met.
Sentencing and Civil Liabilities
The appellate court imposed an indeterminate sentence on Artemio Aquino, ranging from eight years and two months to fourteen years
...continue readingCase Syllabus (G.R. No. 126171)
Case Overview
- Title: People of the Philippines vs. Artemio Aquino a.k.a. Artem and Ernesto Aquino a.k.a. Erning
- Court: Second Division
- G.R. No.: 130613
- Date of Decision: October 05, 2000
- Accused: Artemio Aquino a.k.a. Artem, Ernesto Aquino a.k.a. Erning
- Charge: Murder for the killing of Ricardo Junio on July 29, 1984
Factual Background
- The incident occurred on July 29, 1984, in Sitio Parongking, Bgy. San Miguel, Calasiao, Pangasinan.
- Ricardo Junio was allegedly murdered by Artemio Aquino, with Ernesto Aquino's involvement.
- Ernesto was apprehended shortly after the incident, tried, and acquitted.
- Artemio evaded capture until December 1996, when he was arrested and subsequently tried.
- On May 23, 1997, the Regional Trial Court found Artemio guilty of murder, leading to the appeal focused solely on him.
Prosecution's Evidence
- Witness Testimony: Eduardo Barte, a key witness, testified he observed Artemio stab Ricardo while seated on a bamboo bench.
- Details of the Attack:
- Artemio approached Ricardo for conversation before the stabbing.
- Ricardo attempted to flee but was pursued by Ernesto, ultimately falling into the water.
- Eduardo attempted to rescue Ricardo but found him dead upon retrieval from the water.
Defense's Assertions
- Denial of Involvement: Artemio claimed he was at home caring for his children during the incident.
- Chall