Case Summary (A.C. No. 5161)
Facts of the Case
Rommel and his co-accused were charged with murder after an altercation resulted in the death of Gilberto Bedrero. The Amended Information filed on April 10, 2012, noted that the accused, armed with deadly weapons and conspiring together, attacked Gilberto, resulting in stab and hack wounds that led to his death. Following the altercation, both Rommel and Ronelo pleaded not guilty during their arraignment, while Rolando remained at large.
Version of the Prosecution
The prosecution's case relied heavily on the testimonies of witnesses, including family members of the victim. Philip Bedrero, Gilberto's cousin, testified that an argument between Ronelo and himself escalated, with Ronelo later returning armed with a bolo and demanding Philip come out. Gilberto, in an effort to pacify Ronelo, emerged from the house but was ambushed by Rommel and Rolando, resulting in a brutal attack with various weapons. Witnesses described Rommel striking Gilberto with an ax, followed by further attacks by Ronelo and Rolando, leading to Gilberto’s fatal injuries.
Version of the Accused-Appellant
Rommel provided a defense claiming he was merely returning from a gathering with friends when he witnessed the altercation unfold. His version of events claimed that Philip instigated the fight with Ronelo, leading to an outburst of violence. Rommel argued that he was not involved in the initial assault and tried to distance himself from the attack on Gilberto, stating he fled when threatened by Philip.
RTC Ruling
The Regional Trial Court (RTC) rendered a judgment finding Rommel guilty of murder. It concluded beyond reasonable doubt that Rommel and Ronelo conspired to kill Gilberto, with acts demonstrating treachery and the abuse of superior strength. The RTC imposed a sentence of reclusion perpetua and mandated the payment of damages to Gilberto’s heirs, including civil, moral, nominal, exemplary damages, and attorney's fees.
CA Ruling
Upon appeal, the Court of Appeals (CA) upheld the RTC's decision, affirming the findings on the credibility of prosecution witnesses and the established conspiracy between the accused. The CA did, however, clarify that the finding of abuse of superior strength was absorbed by the presence of treachery, confirming Rommel's complicity and affirming the sentencing.
Issue on Appeal
Rommel challenged the conviction, asserting that the testimonies of the prosecution witnesses, particularly Philip and Grace Bedrero, were untrustworthy due to their familial connection to the victim and claims of intoxication affecting their reliability. He also contended that the physical evidence (the cause of death) contradicted the witnesses' accounts.
The Court's Ruling
The Supreme Court concluded that the appeal was without merit. It found the evaluative function of the trial court regarding witness credibility should be respected absent clear error. Testimonies from Philip and Grace provided a coherent narrative of the events leading to Gilberto's death. The Court addressed Rommel’s claims about intoxication, noting that the eyewitness accounts were not impaired, particularly given that no substantial evidence of significant intoxication was established. The Court upheld that treachery was evident as the attack was executed without warning, significantly impairing Gilberto's ability to defend himself.
Conspiracy and Criminal Liability
The ruling emphasized that conspiracy can be inferred from the concerted action of the accused in a violent crime, whereby each member
...continue readingCase Syllabus (A.C. No. 5161)
Case Information
- Jurisdiction: Supreme Court of the Philippines
- Date of Decision: July 04, 2018
- Case Number: G.R. No. 225322
- Division: Third Division
- Judges: MARTIRES, J.; Velasco, Jr., Bersamin, Leonen, and Gesmundo, JJ. concurred.
Background
- This case involves an appeal from the June 26, 2015 Decision of the Court of Appeals (CA) which upheld with modification the January 27, 2014 Judgment of the Regional Trial Court (RTC) of Naga City.
- The RTC found accused-appellant Rommel Bermudo y Capistrano guilty of murder under Article 248 of the Revised Penal Code for the death of Gilberto Bedrero.
Charges and Accusation
- The amended information dated April 10, 2012, charged Rommel, along with co-accused Ronelo Bermudo y Marcellano and Rolando Bermudo y Capistrano, with murder.
- The accusation alleged that on March 7, 2012, in Barangay San Francisco, Canaman, Camarines Sur, the accused conspired to kill Gilberto Bedrero, armed with deadly weapons, resulting in multiple stab and hack wounds leading to his death.
Prosecution's Version
- Key witnesses included relatives of the victim and medical professionals:
- Philip Bedrero (Cousin): Witnessed the initial argument and later the assault.
- Grace Bedrero (Niece): Saw the attack on Gilberto and was ordered away by Ronelo.
- Lolita Bedrero (Wife): Provided context but was not a direct witness.
- Dr. Geyser H. Agustin and Dr. Raoul V. Alcantara: Provided medical testimony regarding the cause of death.
- PO3 Manuel San Agustin, Jr.: Testified regarding the identification and arrest of the accused.
- The