Case Summary (G.R. No. 242255)
Charges and Proceedings
On March 13, 2001, the appellant, Rael Delfin, was formally charged with murder under Article 248(1) of Act No. 3815, also known as the Revised Penal Code (RPC). The information stated that on or about September 27, 2000, in Navotas, the appellant, armed and with intent to kill, attacked Emilio Enriquez, resulting in his death from gunshot wounds.
Trial and Evidence
During the trial, the prosecution presented witness testimonies, including Joan Cruz, the live-in partner of the victim, and Dr. Jose Arnel Marquez, a forensics doctor. Joan witnessed the shooting and confirmed that the appellant was present at the scene and fired multiple shots at Emilio. Dr. Marquez provided post-mortem evidence detailing the fatal gunshot wounds sustained by the victim.
Conversely, the defense relied on alibi testimony from Rael Delfin and his companion, Rene Villanueva. Delfin asserted that he was fishing in Bataan at the time of the murder. However, Rene's testimony later contradicted the timeline, indicating they returned to Navotas around the time of the shooting.
Judgment of the RTC
On July 20, 2009, the RTC convicted Delfin of murder and sentenced him to reclusion perpetua, along with an order to pay civil indemnity and consequential damages. The appellant appealed this decision to the Court of Appeals.
Court of Appeals Decision
On April 29, 2012, the Court of Appeals affirmed the RTC’s decision but modified the damages awarded. The appellate court replaced the consequential damages with moral damages, still affirming the conviction based on the merits of the case.
Grounds for Appeal
The appellant contested the accuracy of the information used to indict him, highlighting that the alleged date of the offense in the charge was incorrect and that such discrepancies impaired his ability to prepare an adequate defense. Furthermore, he questioned the credibility of the prosecution's witness and the finding that treachery was present during the commission of the crime.
Judicial Rulings on Appeal
The Court ruled that the variance in the date of the offense as alleged in the information and as established during the trial did not invalidate the information. Because the actual commission date is not a material element for the charge of murder, the precision of the date was not essential. The Rules of Court require that the date be approximated, thus upholding the validity of the information despite the clerical error.
Alibi Defense Review
The Court also found the appellant’s alibi unpersuasive, citing established jurisprudence that generally upholds the findings of the trial court. The testimony from Joan provided critical, credible evidence against the appellant, while the alibi presented was both weak and unconvincing given that it did not establish physical impossibility for the appellant to be present at the crime scene.
Treachery Evaluation
The Court validated the class
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Case Background
- This case concerns an appeal from Rael Delfin, contesting the Decision dated 29 April 2011 of the Court of Appeals (CA) in CA-G.R. CR-H.C. No. 04160.
- The CA affirmed with modification the conviction of Rael Delfin for murder under Article 248(1) of Act No. 3815, the Revised Penal Code (RPC).
- The murder took place on the night of 27 September 2000, involving the victim, Emilio Enriquez, a 51-year-old fisherman from Navotas City.
Incident Details
- Emilio was shot while talking on the phone at a store across from his home.
- Eyewitness Joan Cruz, Emilio's live-in partner, testified that she witnessed the shooting and identified the appellant as the shooter.
- Joan reported hearing a gunshot moments after going inside the house, followed by seeing Emilio shot and the appellant firing additional shots.
- The absence of prior altercation between Emilio and the appellant was noted in her testimony.
Medical Examination
- Dr. Jose Arnel Marquez, a police physician, conducted a post-mortem examination and issued a Medico-Legal Report stating that Emilio died from two gunshot wounds - one to the head and another to the chest.
Defense Argument
- Rael Delfin presented an alibi, claiming he was fishing in Bataan during the time of the shooting, accompanied by three others, including Rene Villanueva.
- However, Rene later contradicted the appellant's timeline, stating they returned to shore in Navotas City before the shooting occurred.