Case Summary (G.R. No. L-19650)
Legal Proceedings Overview
The trial progressed through the Regional Trial Court (RTC) Branch 18 in Cebu City, which rendered a decision on September 25, 2014, finding Caliao guilty of murder. The Court of Appeals (CA) later affirmed the decision on May 20, 2016, with modifications regarding civil damages. Caliao subsequently appealed the CA's decision, arguing the existence of self-defense and challenging the credibility of the prosecution's witnesses.
Version of the Prosecution
The prosecution’s case was supported by testimonies from the victim's family, including Virginia Fuentes, William’s wife, and their son, Junnel. They recounted an altercation the night before the stabbing, initiated by Caliao's actions of placing garbage beside their stall. On the day of the incident, the prosecution asserted Caliao attacked William with a kitchen knife, leading to William's death the following day. Witnesses corroborated Virginia and Junnel's accounts, stating that the attack was sudden and unprovoked.
Version of the Defense
Caliao’s defense claimed that he acted in self-defense, alleging that William was the initial aggressor, threatening him with an iron pipe and pouring kerosene on his goods. The defense consisted of testimonies from Caliao, along with two other individuals who supported his version of the events. However, the credibility of these witnesses was later challenged by the prosecution through rebuttal evidence, notably testifying that one defense witness had never seen the accused's family or employees in the market prior to the case.
RTC Ruling
The RTC dismissed the self-defense claim, asserting that the elements necessary to establish self-defense were not met. It found the presence of treachery and evident premeditation, leading to a conviction for murder. The RTC imposed a penalty of reclusion perpetua along with corresponding civil damages to the victim’s heirs.
CA Ruling
The CA upheld the RTC conviction for murder but modified the ruling by removing evident premeditation as an aggravating circumstance while still recognizing treachery. The modifications included increased civil indemnity and moral damages for the victim's family, adjusting the amounts to P75,000 each, along with an increased exemplary damages award.
Present Appeal
In the current appeal, Caliao contended that the CA erroneously upheld his conviction and emphasized self-defense, disputing the credibility of the prosecution witnesses due to their familial relationship to the victim. He maintained that his claim of self-defense had been sufficiently established.
The Court’s Ruling
The Court found Caliao guilty of homicide instead of murder, concluding that self-defense was not clearly proven. The Court reiterated the requirements to establish self-defense, highlighting that unlawful aggression must be proven. It determined that t
...continue readingCase Syllabus (G.R. No. L-19650)
Background of the Case
- The case is an appeal before the Supreme Court of the Philippines concerning the conviction of Nestor "Tony" Caliao for the crime of murder, as adjudicated by the Regional Trial Court (RTC) and subsequently affirmed with modifications by the Court of Appeals (CA).
- The original RTC decision was rendered on September 25, 2014, and the CA's ruling followed on May 20, 2016.
- The case revolves around an incident that occurred on April 25, 2004, in Cebu City, where the accused allegedly stabbed William A. Fuentes, resulting in the latter's death.
Facts of the Case
- An Information was filed on August 20, 2004, charging Caliao with murder, detailing that he attacked Fuentes with a kitchen knife intending to kill him, with treachery and evident premeditation.
- The victim was confronted by the accused over an altercation regarding garbage placement, which escalated into a physical confrontation.
- On the day of the incident, witnesses including Virginia Fuentes (the victim's wife) and Junnel Fuentes (the victim's son) testified that the accused attacked the victim without provocation.
- The accused's defense claimed self-defense, stating that he was attacked first by the victim with an iron pipe and that he acted in response to that aggression.
Prosecution's Evidence
- Virginia Fuentes testified about the altercation leading up to the stabbing and highlighted the sudden nature of the attack by Caliao.
- Junnel Fuentes