Case Summary (G.R. No. 95546)
Overview of Charges and Initial Sentence
Both accused were found guilty of murder, and the trial court sentenced them to death, ordering them to collectively indemnify the heirs of the victim, Ruperto Dizon. The damages included P50,000 for civil indemnity, P6,000 for funeral expenses, and P50,000 for moral damages.
Prosecution Evidence
Witness Romeo Barsaga testified that he observed the two accused simultaneously attack and hack Ruperto Dizon, who was unarmed and posed no threat. According to the autopsy report prepared by Dr. Merlie G. Beltran, Ruperto sustained multiple severe injuries consistent with a brutal attack, leading to his death due to hypovolemia from the wounds.
Defense Testimonies
Joaquin Barrameda contended that he intervened because Ruperto was sexually assaulting his wife. He claimed that upon hearing her screams, he armed himself and attacked Ruperto in defense of his wife. Adolfo Belga maintained he was not present during the attack, asserting he went to sleep after the feast, unaware of the events unfolding outside.
Trial Court Findings
The trial court dismissed the defense claims, emphasizing the credibility of Barsaga’s testimony, which was corroborated by the autopsy findings. It noted that Joaquin's self-defense claim was not substantiated by sufficient evidence, particularly the lack of corroboration from his wife regarding the alleged assault.
Appeal and Rejection of Arguments
On appeal, the accused argued that the trial court erred in not acknowledging their plea of defense of a relative and in fully accepting Barsaga's testimony. However, the appellate court reiterated that the trial court's assessment of witness credibility is entitled to significant deference. The court confirmed that both accused conspired in the attack and effectively acted in concert.
Assessment of Qualifying Circumstances
While the trial court initially characterized the crime as treacherous, the Supreme Court noted that the evidence did not support this classification as the eyewitness did not see the initiation of the attack. It pointed out that treachery must be established beyond doubt and concluded that any ambiguity should favor the accused. However, it affirmed that the attack was significantly marked by the accused's abuse of superior strength, as they were armed with bolos while the victim was unarmed.
Final Sentencing and Civil Damages
The Supreme Court agreed to modify the initial sentence from death to reclusion perpetua, aligning with the
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Case Background
- The accused, Joaquin Barrameda and Adolfo Belga, were charged with the murder of Ruperto Dizon, allegedly conspiring and aiding one another in his stabbing and hacking.
- The trial court found both guilty of murder on May 20, 1997, and sentenced them to death. They were ordered to indemnify the heirs of the victim for damages incurred.
Incident Description
- The incident occurred on June 9, 1996, during a barangay fiesta in Tanagan, Bacacay, Albay.
- Witness Romeo Barsaga testified that he saw the accused simultaneously attacking Ruperto Dizon with bolos while he was unarmed.
- The victim was attacked from the front and behind, leading to his death from multiple wounds.
Autopsy Findings
- Dr. Merlie G. Beltran conducted an autopsy on June 10, 1996. The findings included:
- Multiple hacked and stab wounds, resulting in hypovolemia due to significant blood loss.
- Specific injuries detailed included wounds to the scalp, head, shoulder, chest, arm, neck, and back.
Defense Testimonies
- Joaquin Barrameda claimed that he acted to defend his wife from Ruperto, alleging that Ruperto was assaulting her.
- Adolfo Belga provided an alibi, stating he had been with his family and did not witness