Case Summary (G.R. No. 76743)
Nature of the Appeal
This appeal arises from the decision of the Regional Trial Court of Quezon City, Branch 99, which found the accused guilty of homicide and parricide. The trial court sentenced Arturo de Vera to ten years and one day to fourteen years and eight months of imprisonment, Jaime Caranzo to twelve to fourteen years and eight months of imprisonment, and Rosemarie Balignasay to life imprisonment.
Charges Against the Accused
The amended information charged Rosemarie Balignasay with parricide, while Jaime Caranzo and Arturo de Vera were charged with murder. The prosecution alleged that all three conspired to kill Antonio Eugenio, Jr. They were accused of stabbing him multiple times, leading to his death.
Prosecution's Evidence
The prosecution provided multiple pieces of evidence, including the autopsy report from Dr. Dario Gajardo, who testified about the stab wounds on the victim's body. According to his findings, the cause of death was "cardio-respiratory arrest due to shock and hemorrhage secondary to stab wounds." Additionally, testimonies from the victim’s mother, Cristina Eugenio, and brother, Rodrigo Eugenio, supported the prosecution's case, detailing an altercation that occurred prior to the victim being fatally stabbed.
Defense's Version of Events
The defense claimed self-defense by Arturo de Vera, asserting that the victim ambushed him with a knife, and he was forced to retaliate. Both Rosemarie and Jaime Caranzo denied their involvement in the crime, asserting they had no knowledge of the attack.
Evaluation of the Evidence and Conspiracy
The crux of the appeal involved the alleged conspiracy among the accused. The trial court found that there was a concert of action between the parties, characterized by joint participation in the stabbing of the victim. The defense argued that the prosecution's evidence failed to prove conspiracy beyond a reasonable doubt, citing inconsistencies in the testimonies of prosecution witnesses, particularly concerning the location of the stabbing.
Appellant's Assignments of Error
Rosemarie Balignasay raised four main assignments of error, asserting that the trial court erred in various aspects concerning motive, the sequence of events leading to the stabbing, and the existence of conspiracy. She contended that if the fatal wound was inflicted inside the house, the victim could not have fled to the location where he was eventually found.
Legal Principles Relevant to Conspiracy
It was emphasized that in cases of conspiracy, the act of one is considered the act of all. A
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Case Citation
- G.R. No. 76743
- Date of Decision: May 22, 1992
- Jurisdiction: Supreme Court of the Philippines
Overview of the Case
- This case involves three accused—Jaime Caranzo y Catindig, Arturo de Vera y Carlos, and Rosemarie Balignasay—who were tried for the murder of Antonio Eugenio, Jr.
- The Regional Trial Court of Quezon City found the accused guilty, with varying penalties and charges against each.
Charges and Verdicts
Arturo de Vera y Carlos
- Charged with Homicide under Article 249 of the Penal Code.
- Verdict: Guilty beyond reasonable doubt.
- Sentenced to an indeterminate penalty of 10 years and 1 day of prision mayor to 14 years and 8 months and 1 day of reclusion temporal.
Jaime Caranzo y Catindig
- Also charged with Homicide under Article 249.
- Verdict: Guilty beyond reasonable doubt.
- Sentenced to an indeterminate penalty of 12 years of prision mayor to 14 years and 8 months and 1 day of reclusion temporal.
Rosemarie Balignasay
- Charged with Parricide under Article 246.
- Verdict: Guilty beyond reasonable doubt.
- Sentenced to Life Imprisonment (reclusion perpetua).
Indemnity and Damages
- All three accused were ordered to pay jointly and severally:
- P30,000.00 as indemnity to the heirs of Antonio Eugenio, Jr.
- P3,975.00 in actual damages.
- P50,000.00 in moral damages.
- They were also granted full credit for preventive imprisonment.
Facts of the Case
- The incident occurred on August 1, 1983, in Quezon City, involving a conspiracy among the accused to kill Antonio Eugenio, Jr.
- The prosecution presented evidence including:
- Testimony from Dr. Dario L. Gajardo, who conducted the autopsy, detailing multiple stab wounds and the cause of death