Case Summary (G.R. No. 245969)
Antecedents
The prosecution issued two separate Informations: one charging the four accused with murder and another charging Poly with attempted murder against a different individual, Rodel Cagus y Apostol. The murder Information detailed how the accused, armed with bladed weapons and wood, conspired to kill the victim by inflicting multiple stab wounds that ultimately caused his death.
Version of the Prosecution
The prosecution called six witnesses, including the victim’s wife, Lydia, who recounted that after a commotion outside their home, her husband was attacked by Manuel Catulang and three other men, who dragged him inside a house and assaulted him with various weapons. Other witnesses corroborated Lydia’s account, emphasizing the brutality of the assault and the presence of weapons used during the attack.
Version of the Defense
In contrast, the defense claimed that the accused were acting in self-defense. They alleged that the victim initiated the violence by attacking Manuel with an ice pick, prompting the others to respond. Each accused provided varying testimonies, with Poly admitting to stabbing Romy but claiming fear for their safety justified his actions. Crispolo was said to have been unaware of the events as he was inside another room.
Ruling of the Regional Trial Court
The Regional Trial Court (RTC) found the accused guilty of murder and imposed a sentence of reclusion perpetua. The RTC concluded that there was conspiracy among the accused, evident from their coordinated actions during the attack on Romy. The RTC found that the attack was characterized by abuse of superior strength, as the accused were armed and outnumbered the unarmed victim.
Ruling of the Court of Appeals
The Court of Appeals (CA) upheld the RTC’s ruling, rejecting claims of self-defense and defense of a relative. The CA supported the inference of conspiracy and noted a distinct lack of unlawful aggression from the victim, emphasizing that the attackers took advantage of their numerical superiority and used excessive force. The CA dismissed the mitigating circumstances raised by the accused, particularly regarding voluntary surrender.
Issues
In their appeal, the accused raised several issues, including the alleged failure of the prosecution to prove conspiracy and their claims of self-defense. They asserted that their guilt was not established beyond a reasonable doubt and that their individual culpability was not properly assessed.
Ruling of the Supreme Court
The Supreme Court acknowledged that an appeal in criminal cases allows for a comprehensive review. It upheld the findings of the lower courts regarding self-defense and conspiracy. The Court highlighted that the testimony provided by the defense did not substantiate claims of unlawful aggression or injury to justify the actions of the accused.
Absence of Unlawful Aggression
The Court reiterated that proper self-defense requires clear evidence of unlawful aggression from the victim, which was not substantiated by the defense's claims. The accounts indicated that Romy was unarmed and not a threat by the time he was attacked, leading to the failure of the claims of self-defense.
Establishment of Conspiracy
While the lower courts placed significance on conspiracy, the Supreme Court found that the evidence did not sufficiently establish that Joel participated actively in the conspiracy. It concluded that Joel’s actio
...continue readingCase Syllabus (G.R. No. 245969)
Case Background
- The case revolves around G.R. No. 245969, decided on November 03, 2020, by the First Division of the Supreme Court of the Philippines.
- The appeal is from a decision of the Court of Appeals (CA) affirming the Regional Trial Court (RTC) of Caloocan City, which found the accused guilty of murder under Article 248 of the Revised Penal Code (RPC).
- The principle of presumption of innocence is emphasized, stating that doubt on the guilt of the accused mandates acquittal.
Antecedents
- The case originated from two separate Informations that charged the accused with murder and attempted murder. The incidents occurred on September 7, 2008, in Caloocan City.
- The first Information charged Joel, Poly, Crispolo, and Manuel Catulang y Villegas with the murder of Romeo Cantiga y Mantalaba, detailing the use of bladed weapons and a plan to kill.
- The second Information charged Poly with attempted murder against Rodel Cagus y Apostol, indicating that Poly did not complete the crime due to the timely arrival of neighbors.
Prosecution's Version
- Six witnesses were presented by the prosecution, including Lydia Cantiaga, the victim’s wife, and various police officials.
- Lydia testified that she and her husband were attacked by the accused while trying to ascertain the cause of a commotion outside their home, identifying the assailants as Manuel, Joel, Poly, and Crispolo.
- Witness Jonathan Rebose corroborated Lydia's account, describing how Romy was dragged inside the house and attacked.
- Police Chief Inspector Editha Martinez conducted the autopsy, confirming multiple stab wounds as the cause of death.
- Eutequio Seming Jr., the Purok leader, and police officers provided testimony regarding the recovery of weapons and the condition of the accused post-incident.
Defense's Version
- The defense claimed that the a