Case Summary (G.R. No. 172871)
Antecedent Facts
Clemente Casta was charged with murder for the fatal stabbing of Danilo Camba. The prosecution's Information detailed that on the afternoon of August 20, 1989, Casta, with intent to kill and by means of treachery, attacked Camba with a knife, inflicting fatal wounds. Casta pleaded not guilty during his arraignment.
Testimonies and Evidence
Various witnesses testified against Casta, including Marlyn Cister, who observed Casta stab Camba from behind as Camba stood roadside, and Modesto Cardona, who corroborated her account. Domingo Camba, a police officer, described the investigation that followed. Casta, in his defense, claimed he acted in self-defense but failed to establish any unlawful aggression from Camba.
Trial Court Ruling
On August 18, 1999, the Regional Trial Court convicted Casta of murder, imposing a sentence of reclusion perpetua and ordering him to pay damages to the heirs of the victim, namely P50,000 for death indemnity, P100,000 for moral and exemplary damages, and P13,000 for actual damages.
Court of Appeals Decision
The Court of Appeals upheld the trial court's decision on March 10, 2006. Casta appealed, arguing the trial court's errors in conviction and penalty.
The Court's Ruling on Appeal
The Supreme Court conducted a thorough review of the lower court's factual findings, which are generally given deference. Casta's admission of stabbing Camba was pivotal, indicating a lack of credible self-defense claims. The prosecution successfully proved beyond reasonable doubt that Casta committed murder with the qualifying circumstance of treachery, given the sudden and surprise nature of the attack, depriving Camba of any opportunity for self-defense.
Self-Defense Argument
Casta's assertion of self-defense was rejected. The essential elements of self-defense under Article 11 of the Revised Penal Code were not established. Casta failed to provide corroborating evidence for his claim of unlawful aggression from Camba, while eyewitness accounts contradicted his version of events.
Mitigating Circumstances and Voluntary Surrender
Despite the findings of guilt, the Court recognized Casta's voluntary surrender to the police, which serves as a mitigating circumstance. His surrender, occurring within a day after the incident, reflected an acknowledgment of guilt and resulted in a modification of his sentence.
Appropriate Penalty
The Court clarified that the crime of murder occurred in 1989, prior to the amendments introduced by Republic Act No. 7659, which imposes a heavier penalty. Therefore, Casta's sentence needed to align with the legal framework in place at the time of the offense. Casta was sentenced to an indeterminate penalty of 10 years and 1 day of prision mayor maximum as t
...continue readingCase Syllabus (G.R. No. 172871)
Case Citation
- Court: Supreme Court of the Philippines
- Division: Second Division
- Case Number: G.R. No. 172871
- Decision Date: September 16, 2008
- Appeal from: Court of Appeals Decision dated March 10, 2006
- Lower Court: Regional Trial Court (RTC), Branch 55, Alaminos, Pangasinan
- Original Decision Date: August 18, 1999
Background of the Case
- The case involves an appeal by Clemente Casta y Carolino against his conviction for murder.
- The RTC found him guilty beyond reasonable doubt and sentenced him to reclusion perpetua.
- The appellant was charged with murdering Danilo Camba on August 20, 1989, in Barangay Goyoden, Bolinao, Pangasinan.
Antecedent Facts
Charge Details:
- The Information charged the appellant with murder, citing intent to kill and treachery.
- The specific nature of the attack involved stabbing Danilo Camba with a knife, resulting in fatal injuries.
Incident Description:
- Multiple witnesses testified about the events leading to the stabbing.
- Marlyn Cister saw the appellant stab Danilo from behind, causing Danilo's immediate death.
- Modesto Cardona corroborated this account, stating Danilo was unarmed and had been walking with friends.
Witness Accounts:
- Witnesses included Marlyn Cister, Modesto Cardona, Domingo Camba (police officer), Dionisia Camba (Danilo's widow), and Dr. Prudencio C. de Perio (medical examiner).
- Medical findings confirmed the fatal injuries sustained by Danilo, including stab wounds to the back and forearm.
Defense and Testimony
- The appellant claimed that the stabbing was accidental and asserted self-defense.
- He testified about an encounter with an unknown person who allegedly attacked him first.
- The appellant's version of events contradicted witness testimonies, which did not support his claims of provo