Case Summary (G.R. No. 229502)
Facts of the Case
Rafael Daroya was charged with Murder under Article 248 of the Revised Penal Code. The Information alleged that on October 19, 2002, Daroya attacked Rolando Songcuan, causing his death from head injuries due to continuous mauling. Upon arraignment, Daroya pleaded not guilty. The trial included witness testimonies, showing that Daroya assaulted Rolando with a metal object, resulting in serious injuries that led to the latter's death.
Trial and Lower Court Rulings
During the trial, the prosecution presented testimonies from several witnesses, including Dr. Bautista and a pedicab driver, Ceralde, who identified Daroya as the attacker. Daroya admitted to punching Rolando but claimed self-defense, alleging that Rolando initiated the fight. On February 24, 2014, the Regional Trial Court found Daroya guilty of Murder and sentenced him to reclusion perpetua, along with several monetary damages to Rolando's heirs.
Appeal to the Court of Appeals
Daroya appealed the RTC's decision, arguing that the prosecution failed to meet the burden of proof for Murder and that there was provocation that justified his response. On February 15, 2016, the Court of Appeals affirmed the RTC's ruling but modified the monetary awards.
Issues for Resolution
The primary issue is whether the Court of Appeals erred in affirming the RTC's Decision that found Daroya guilty of Murder beyond a reasonable doubt.
Ruling of the Court
The Supreme Court found that the appeal was partly meritorious. For a conviction of Murder, the essential elements under Article 248 of the RPC must be met, including the presence of qualifying circumstances such as treachery. The Court acknowledged that while Daroya admitted to inflicting fatal injuries, he bore the burden to prove self-defense, which requires an unlawful aggression on his part that was not established in this case.
Self-Defense Plea
Daroya's claim of self-defense was analyzed, highlighting that he failed to demonstrate the presence of unlawful aggression by Rolando. The evidence overwhelmingly showed that Daroya was the aggressor. The Court emphasized that claims of self-defense must satisfy specific conditions, which were not met.
Findings on Treachery
The Court concluded that the prosecution did not sufficiently prove the qualifying circumstance of treachery. The lower courts erroneously associated the suddenness of the attack with treachery without demonstrating that Daroya intentionally employed a means of attack that prevented Rolando from defending himself. This finding led the Court to reject the treachery qualification.
Modification of the Charge
Due to the lack of established treachery, the Supreme Court downgraded Daro
...continue readingCase Syllabus (G.R. No. 229502)
Case Overview
- Case Citation: 820 Phil. 847
- Decided by: Second Division
- G.R. No.: 229502
- Date of Decision: November 08, 2017
- Parties: People of the Philippines (Plaintiff-Appellee) vs. Rafael Daroya @ Raffy (Defendant-Appellant)
Procedural History
- The case originates from a Decision dated February 15, 2016, rendered by the Court of Appeals (CA) in CA-G.R. CR-HC No. 06761, which affirmed with modification the conviction of Rafael Daroya for murder by the Regional Trial Court (RTC) of Dagupan City, Branch 42, through its Decision dated February 24, 2014.
Facts of the Case
- Daroya was charged with murder as defined under Article 248 of the Revised Penal Code (RPC) for the death of Rolando Songcuan, described in an Information dated February 18, 2003.
- The Incident occurred on October 19, 2002, in Dagupan City. The accusatory portion alleged that Daroya, with treachery and intent to kill, attacked Rolando, leading to his death from head injuries and massive hemorrhage.
- Daroya entered a plea of not guilty during arraignment, leading to a trial where the prosecution presented witnesses, including Dr. Bautista, Herminina Songcuan, and Arnel Ceralde, while Daroya presented his own testimony.
Prosecution's Allegation
- Ceralde, a pedicab driver, testified that he witnessed Daroya appear suddenly, holding a metal object wrapped in a towel, and punch Rolando repeatedly, causing him to fall and subsequently die after being taken to the hospital.
- Dr. Baut