Case Summary (G.R. No. 223103)
Facts of the Case
Alex De Los Santos was indicted for the murder of Fernando A. Catriz, which occurred on April 6, 2004. The charge outlined that De Los Santos, armed with a long bolo, attacked and hacked Catriz from behind, inflicting multiple stab wounds that led to Catriz's death. Notably, the incident took place while Catriz and a witness, Reynaldo Bayudan, were unloading chickens. Eyewitness accounts indicated that Catriz was significantly outmatched, even begging for his life, while De Los Santos continued the attack. Following the altercation, De Los Santos exhibited a lack of remorse, publicly expressing a grim satisfaction upon realizing Catriz was dead.
Proceedings and Evidence
During the trial, the prosecution presented eyewitness testimony from Bayudan and medical evidence from Dr. Exuperio Yuaga, who conducted a post-mortem examination confirming that Catriz died from multiple stab wounds, with several wounds being fatal. The defense claimed self-defense, alleging that Catriz had attacked De Los Santos first. However, this narrative was contradicted by testimony that showed De Los Santos was the initial aggressor.
Ruling of the Regional Trial Court (RTC)
The RTC found De Los Santos guilty of murder, dismissing self-defense as a credible argument. The court ruled that treachery characterized the crime, as Catriz was attacked from behind and was in a defenseless position, with De Los Santos continuing to stab even after the victim had fallen to his knees. The RTC imposed a sentence of reclusion perpetua and mandated civil indemnities to the victim’s heirs.
Ruling of the Court of Appeals (CA)
The CA upheld the RTC's decision, stating that there was no merit to the self-defense claim raised by De Los Santos. The CA highlighted that De Los Santos's failure to demonstrate any immediate threat from Catriz significantly weakened his defense. The court reiterated that the sequence and nature of the wounds indicated a predetermined intent to kill.
Supreme Court Ruling
The Supreme Court affirmed the lower courts' decisions, reaffirming the rejection of self-defense based on the prosecution's credible evidence. It underscored the evidentiary burden on De Los Santos to prove his claim of self-defense after acknowledging he had committed the act. The court highlighted that the absence of unlawful aggression by Catriz precluded any viable self-defense claim. The attack was deemed premeditated, executed without warning, thus fulfilling the conditions for treachery.
Penalty and Damages
De Los Santos was sentenced to reclusion perpetua without parole eligibility, aligning with
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Case Information
- Court: Supreme Court of the Philippines
- Date: July 23, 2014
- G.R. No.: 207818
- Division: First Division
- Decision: Affirmed with modifications
Parties Involved
- Plaintiff-Appellee: People of the Philippines
- Accused-Appellant: Alex De Los Santos
Procedural History
- The case is a review of the Decision dated September 17, 2012, from the Court of Appeals (CA) in CA-G.R. CR-HC No. 03790.
- The CA affirmed the Judgment dated January 7, 2008, from the Regional Trial Court (RTC) of Tuao, Cagayan, Branch 11, in Criminal Case No. 1165-T, convicting Alex De Los Santos of murder.
Facts of the Case
- Incident Date: April 6, 2004
- Location: Barangay Mungo, Tuao, Cagayan
- Victim: Fernando A. Catriz
- Relationship: Catriz and De Los Santos were brothers-in-law; Catriz was the husband of De Los Santos' sister.
- Details of the Attack:
- Catriz and Reynaldo Bayudan were unloading chickens when De Los Santos attacked.
- De Los Santos used a long bolo to hack Catriz on the shoulder.
- After the initial attack, De Los Santos pursued Catriz with a Rambo-type knife, inflicting multiple stab wounds despite Catriz pleading for his life.
- Catriz sustained 11 stab wounds, four of which were fatal, and died from hypovolemic shock.
- Witnesses:
- Prosecution: Reynaldo Bayudan (eyewitness), Dr. Exuperio Yuaga (post-mortem examination).
- Defense: Alex De Los Santos (accused), Joseph Aginawang (uncle of the accused).
Ruling of the RTC
- Date of Decision: January 7, 2008
- Key Findings:
- The RTC found De Los Santos guilty of murder, emphasizing the treachery involved in the attack.
- De Los Santos'