Case Summary (G.R. No. 128126)
Background of the Case
On August 10, 1994, Provincial Prosecutor Dante H. Diamante filed an information charging Rafael M. Catapang with murder. The allegation specified that on July 2, 1994, Catapang, armed with a .45 caliber handgun, shot Rictorino Aventurado multiple times, resulting in the latter's death. At the arraignment on August 24, 1994, Catapang pleaded not guilty.
Incident Details
Witness Jonathan Garcia testified that on the night of the shooting, he saw Catapang attacking Aventurado while he was inside a tricycle. Despite being scared, Garcia observed the assailant shooting at Aventurado, which led to the victim being taken to Bolanos Hospital, where he was pronounced dead on arrival.
Witness Testimonies
Two security guards, Joselito Conyado and Pedrito Mandigma, also witnessed the incident and identified Catapang as the gunman when police conducted an identification lineup shortly after the event. Autopsy results revealed Aventurado sustained multiple gunshot wounds. The police conducted a paraffin test on Catapang, who tested positive for gunpowder residue.
Defense Claims
Catapang denied the accusations, asserting that he was asleep at home during the incident. He acknowledged testing positive for gunpowder residue but claimed it was due to a previous event where he handled a firearm at a baptismal party.
Trial Court's Decision
On December 27, 1995, the trial court found Catapang guilty of murder, sentencing him to reclusion perpetua and ordering him to pay damages to the victim's heirs. The court awarded P50,000 for unrealized income, P50,000 as death indemnity, P65,000 for actual expenses, and P20,000 for moral damages.
Appeal and Credibility of Witnesses
Catapang appealed the decision, contesting the credibility of eyewitness testimony. However, the appellate court upheld the trial court's assessment, noting that the lighting conditions allowed the witness to have a clear view of the assailant. The credibility and demeanor of witnesses were considered sufficient to warrant belief in their accounts.
Alibi Defense
The appellate court ruled that for an alibi to be convincing, Catapang needed to provide irrefutable proof that he was at home and that it was impossible for him to be present at the crime scene. The court found this insufficient since his residence was only about 150 meters from where the shooting occurred.
Qualification of the Crime
Treachery was established as Catapang had ambushed the unarmed victim, fitting the legal definition of treachery, which involves an unexpected attack without risk to the offender. Thus, the appellate court agreed with the lower court’s conclusion that the kil
...continue readingCase Syllabus (G.R. No. 128126)
Case Overview
- This case is an appeal from the decision of the Regional Trial Court, Lucena City, Branch 54.
- Accused Rafael M. Catapang was convicted of murder and sentenced to reclusion perpetua.
- He was also ordered to indemnify the heirs of the victim, Rictorino Aventurado, with various amounts for unrealized income, death indemnity, actual expenses, and moral damages.
Facts of the Case
- On July 2, 1994, at around 9:30 PM, Rictorino Aventurado boarded a tricycle parked along Cabunyag Street, Candelaria, Quezon.
- Jonathan Garcia, the tricycle driver, heard gunshots and saw a person pointing a .45 caliber handgun at Aventurado.
- Garcia observed the gunman shoot Aventurado multiple times before fleeing the scene.
- The area was well-lit, allowing Garcia to identify the shooter, who was later identified as Rafael M. Catapang.
- Aventurado was pronounced dead upon arrival at Bolanos Hospital.
- The police investigation led to the identification of Catapang as the shooter based on witness accounts.
- A post-mortem examination revealed that Aventurado sustained 11 entry wounds and 9 exit wounds, confirming a close-range shooting.
- Catapang tested positive for gunpowder residue, though he claimed it was due to firing a gun earlier that day at a baptismal party.
Trial Proceedings
- Catapang pleaded not guilty during his arraignment.
- Witness testimonies, including that of Garcia and security guards Joselito Conyado and Pedrito Mandigma, formed the basis o