Case Summary (G.R. No. 126749)
Factual Antecedents
An amended information charged the appellants with the murder of Joseph Nicolas, alleging that they acted in conspiracy with intent to kill. On the night of the incident, after an altercation at an abingohan (a social gathering place), Randy punched Joseph, prompting Joseph to chase him. Later, Joseph was confronted by the three appellants, all armed with bolos, resulting in a fatal attack. Witnesses, including the victim’s children, testified seeing the appellants hack Joseph multiple times until he fell to the ground, after which they returned to strike him again, indicating the intent to kill.
Trial Court Ruling
The trial court ruled that the appellants had conspired in the crime, finding clear evidence of murder marked by the abuse of superior strength, given the overwhelming force exhibited by three armed attackers against an unarmed victim. They were sentenced to reclusion perpetua and ordered to pay damages including civil indemnity, moral damages, and exemplary damages.
Court of Appeals Ruling
On appeal, the Court of Appeals affirmed the trial court's decision, modifying the damages awarded. Civil indemnity was increased and exemplary damages reduced. The appellants maintained their innocence, claiming self-defense for Ronald and raising issues about inconsistencies in witness testimonies.
Issues Raised on Appeal
The appellants raised several arguments, including a claim that the trial court failed to properly consider the defense of relatives, disputed the guilt of Rolando and Randy, questioned the credibility of prosecution witnesses due to alleged inconsistencies, and contended that the prosecution failed to prove the qualifying circumstance of abuse of superior strength.
Ruling on Credibility of Witnesses
The Supreme Court emphasized that the factual findings of the trial court, particularly regarding the credibility of eyewitnesses, are generally binding unless proven contrary. Despite claims of inconsistency from the defense, testimonies by the victim's son Russel and nephew Francis were found to corroborate each other and were credible, identifying the appellants unequivocally.
Defense Claims
The appellants argued that Ronald acted in self-defense. The Court clarified that for a valid claim of self-defense or defense of relatives, unlawful aggression must be present. In this case, Joseph was unarmed and did not exhibit any unlawful aggression, undermining the self-defense claim.
Conclusion on Conspiracy and Abuse of Super
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Case Citation
- Jurisprudence: 713 Phil. 438
- Court: Second Division
- G.R. No. 197360
- Date: July 03, 2013
Overview
- This case is an appeal from the Decision of the Court of Appeals, which affirmed with modifications the Decision of the Regional Trial Court.
- The accused-appellants Ronald Credo a.k.a. Ontog, Randy Credo, and Rolando Credo y San Buenaventura were found guilty of murder for the death of Joseph Nicolas.
Factual Antecedents
- Incident Date: June 22, 2005, around 10:30 PM.
- Location: Zone 4, Barangay San Jose, Municipality of Pili, Camarines Sur, Philippines.
- Victim: Joseph Nicolas y Arroyo was attacked by the accused-appellants.
- Details of Assault:
- Randy Credo initiated the attack by punching Joseph.
- Following the initial attack, Randy fled but was later joined by Ronald and Rolando, both armed with bolos.
- Witnesses, including Joseph's children and a neighbor, observed the attack, noting the assault's brutality and the victim's unarmed state.
- Joseph sustained multiple hack wounds, resulting in his death on the same day.
Rulings
Regional Trial Court
- Found all three accused-appellants guilty of murder, citing conspiracy and abuse of superior strength.
- Sentenced to reclusion perpetua and ordered to pay damages to the victim's widow.
Court of Appeals
- Affirmed the trial court's conviction but modified the damages awarded:
- Civil indemnity increased from P50,000.00 to P75,000.00.
- Moral damages increased from P50,000.00 to P75,000.00.
- Exemplary damages reduced from P50,000.00 to P30,000.00.
- Temperate damages of P25,000.00 awarded in lie