Case Summary (G.R. No. 57623)
Charges and Background
Juan and Daniel were charged with murder under Case No. Q-04-125714 and frustrated murder under Case No. Q-04-125715, as part of a larger conspiracy allegedly involving four unidentified individuals. The murder charge stemmed from the fatal attack on Antonio Asistin, while the frustrated murder charge pertained to the attack on Evangeline Cielos-Asistin, who survived the incident. Juan also faced charges for illegal possession of a firearm under Presidential Decree No. 1866.
Prosecution's Case
During the trial, the prosecution presented testimonies from witnesses that included neighbors and law enforcement. These witnesses described the events leading to the stabbing, highlighting the alleged participation of Juan and Daniel in a conspiracy. Evangeline testified that several men, including Daniel, were present during the attack, and claimed that Daniel failed to assist her.
Defense's Position
Both Juan and Daniel pleaded not guilty and denied involvement in the crimes. They argued that the prosecution's evidence was insufficient, highlighting that mere presence at the scene does not establish complicity. They maintained that Daniel, instead of aiding the attackers, helped carry Antonio after the incident.
Trial Court Ruling
The Regional Trial Court (RTC) of Quezon City found both accused guilty of murder and frustrated murder, sentencing them to reclusion perpetua and an indeterminate prison term, respectively. The court primarily relied on the testimonies of the prosecution witnesses to establish the culpability of the accused.
Appeal to the Court of Appeals
Juan and Daniel appealed the RTC's ruling, claiming that the prosecution lacked substantial evidence to prove conspiracy or their direct involvement in the crimes. They contended that circumstantial evidence provided by the prosecution was insufficient for a conviction beyond a reasonable doubt.
Court of Appeals Decision
The Court of Appeals affirmed the RTC's decision, ruling that circumstantial evidence was sufficient to establish guilt, including the claim that Juan and Daniel were seen near the crime scene talking to other unidentified individuals. However, the appellate court acknowledged the lack of direct evidence tying them to the actual stabbing.
Supreme Court Review
Upon review, the Supreme Court determined that both the RTC and the Court of Appeals had ove
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Case Overview
- The case involves an appeal from the Decision dated October 13, 2016, of the Court of Appeals (CA) which found accused-appellants Juan Credo y De Vergara (Juan) and Daniel Credo y De Vergara (Daniel) guilty beyond reasonable doubt of murder and frustrated murder as co-conspirators.
- Juan was also convicted for violation of Presidential Decree No. 1866.
- The appeal was denied and the decision of the Regional Trial Court (RTC) dated September 9, 2013, was affirmed.
Antecedents
- Juan and Daniel were charged with murder and frustrated murder, with the incidents occurring on March 16, 2004, in Quezon City, Philippines.
- The two separate informations detailed the acts committed against Antonio Asistin y Palco (Murder Case) and Evangeline Cielos-Asistin (Frustrated Murder Case).
- Juan faced additional charges related to illegal possession of a firearm under P.D. 1866.
Charges and Allegations
- Murder Case No. Q-04-125714: Allegations included conspiring with others to stab Antonio multiple times, leading to his death.
- Frustrated Murder Case No. Q-04-125715: Allegations involved attempts on Evangeline's life with serious injuries inflicted but not resulting in death.
- Violation of Gun Ban and P.D. 1866: Juan was accused of illegally possessing a homemade shotgun and ammunition during the election period.
Trial Proceedings
- Both Juan and Daniel pleaded not guilty during arraignment, leading to a trial where various witnesses testified about the events of March 16, 2004.
- Prose