Case Summary (G.R. No. L-38180)
Factual Background
The prosecution presented evidence that around four days before the homicide, Waje allegedly lost a sum of money given to him by Crisostomo for purchasing cigarettes and sugar, which led to an altercation. Waje's previous convictions for violent crimes against Crisostomo's former supervisors reportedly fueled the motive for the conspiracy to kill him. On the day of the incident, the accused planned and executed the murder, inflicting multiple stab wounds on the unarmed Waje.
Trial Court's Judgment
Upon review, the trial court convicted both accused based on the overwhelming circumstantial evidence, including their actions leading up to and during the crime. The court found that they acted with treachery and evident premeditation, resulting in the death of Waje. Each was sentenced to death, alongside a requirement to indemnify the victim's heirs.
Testimonies and Evidence
Key evidence included sworn statements from both accused, detailing their conspiracy and actions during the stabbing. Additionally, witness testimony from prison guard Servideo Camarillo corroborated the events described in the confessions. The physical injuries sustained by the accused following their altercation with Waje did not substantiate claims of maltreatment during questioning.
Admissibility of Confessions
The court evaluated the admissibility of the confessions given by the defendants, concluding that they were taken voluntarily without coercion, thereby upholding their integrity under legal standards. The confessions were deemed crucial for establishing their involvement in the conspiracy and the details of the murder.
Conspiracy and Treachery
The existence of conspiracy was evident, given that both accused planned the attack and executed it cooperatively. Crisostomo's acknowledgment of approaching Waje from behind was regarded as an act of treachery, indicative of a calculated effort to eliminate the victim without giving him a chance to defend himself.
Claim of Self-Defense
Crisostomo’s assertion of self-defense was scrutinized against historical evidence and testimonies. The court found insufficient grounds to substantiate his claim, em
...continue readingCase Syllabus (G.R. No. L-38180)
Case Background
- The case pertains to an information filed on July 9, 1973, in the Circuit Criminal Court, Seventh Judicial District, Pasig, Rizal.
- Accused: Salvador Crisostomo and Inocencio Ragsac, charged with murder.
- Date of Incident: May 27, 1972, in the New Bilibid Prison, Muntinlupa, Rizal.
- Victim: Antonio Waje, a sentenced prisoner, who was allegedly killed by the accused while he was unarmed.
Allegations and Charges
- The information alleges that the accused, conspiring together, attacked Waje with treachery, evident premeditation, and deliberate intent to kill, using improvised bladed weapons.
- The attack resulted in multiple stab wounds to Waje, causing his instant death.
- Aggravating circumstances cited include recidivism and quasi-recidivism based on previous convictions of both accused.
Trial Court Proceedings
- The accused both pleaded not guilty during their arraignment.
- On December 28, 1973, Judge Onofre A. Villaluz rendered a judgment finding both accused guilty of murder, sentencing them to death, and ordering them to indemnify the heirs of Waje.
Facts Established During Trial
- Prior to the incident, Crisostomo had given Waje money to procure cigarettes and sugar, which Waje claimed to have lost.
- A confrontation ensued, leading to a conspiracy to kill Waje, particularly fueled by Crisostomo's animosity, as Waje had previously killed prison guards who were friends of Crisostomo.
- On the day of the killing, the