Case Summary (G.R. No. 45100)
Judicial Findings
The trial court found both Epifanio and Roman Diokno guilty of murder, imposing the penalty of reclusion perpetua and ordering them to indemnify the heirs of the deceased in the amount of P1,000. The grounds for their appeal include alleged evidentiary errors, wrongful conviction, and the severity of their sentences.
Crime Details and Evidence
On January 4, 1935, Yu Hiong, a vendor, was engaged to Salome Diokno. After Salome eloped with Yu Hiong, the Diokno family, seeking retribution, located them in Pagbilao and later San Pablo. Yu Hiong was fatally attacked with knives by both Epifanio and Roman Diokno, sustaining several mortal wounds as corroborated by eyewitness accounts and medical examination.
Admissibility of Evidence
The defense contested the admissibility of two exhibits: Exhibit E, a statement made by Yu Hiong shortly after the attack, and Exhibit K, a declaration made before his death. The court upheld their admissibility under urgency and the immediate context surrounding the murder. The court ruled that Yu Hiong was semiconscious at the time of his declarations, qualifying them as ante mortem statements.
Assignments of Error
The appellants argued that the trial court erred in admitting the aforementioned exhibits and in failing to acquit Roman Diokno, whom they contended did not directly partake in the fatal act. They further challenged the sentence imposed on Epifanio, asserting it was excessively harsh given the circumstances.
Role of Ante Mortem Declarations
The court affirmed that the statements made by the deceased were made under a sense of impending death, as they were uttered shortly after the attack while he was gravely injured. Hence, both exhibits were deemed admissible both as ante mortem declarations and part of the res gestae.
Evaluating the Accused's Actions
The court found that both defendants had cooperated in the fatal assault on Yu Hiong. Eyewitness testimony and the nature of the wounds substantiated their involvement. The court concluded that Roman Diokno had indeed inflicted a mortal wound, dismissing the claim of innocence for Roman Diokno.
Mitigating and Aggravating Circumstances
While the trial court had classified the crime as murder based on alleged abuse of superior strength and evident premeditation, the appellate court disagreed. It determined that neither of these circumstances was proven beyond a reasonable doubt. The evidence did not establish that the accused were physically superior to Yu Hiong, nor that their intent to kill was premeditated. Instead, they acted in a moment of passion triggered by the elopement, which counted as mitigating circumstances.
Sentencing Reform
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Case Overview
- The case involves an appeal by Epifanio Diokno and Roman Diokno against the judgment of the Court of First Instance of Laguna.
- The court found both defendants guilty of murder, sentencing them to reclusion perpetua, ordering them to indemnify the heirs of the deceased Yu Hiong in the amount of P1,000, and to pay the costs of the suit.
Allegations of Error
- The appellants raised several alleged errors committed by the lower court:
- Acceptance of Exhibit E as evidence.
- Admission of Exhibit K as evidence.
- Failure to acquit Roman Diokno.
- Erroneous sentencing of Epifanio Diokno to reclusion perpetua.
Factual Background
- Yu Hiong, the deceased, was engaged to Salome Diokno, daughter of Epifanio Diokno.
- On January 4, 1935, Salome invited Yu Hiong to accompany her, despite her father's disapproval.
- On January 7, 1935, Epifanio and Roman Diokno pursued Yu Hiong to San Pablo, Laguna, after learning of his elopement with Salome.
- They confronted Yu Hiong at Antonio Layco's house, where a violent encounter ensued, resulting in Yu Hiong being stabbed multiple times.
Evidence and Testimonies
- Eyewitness Juan Alcantara observed the pursuit and attempted to alert the police.
- Municipal policeman Francisco Curabo discovered Yu Hiong injured and took Epifanio Diokno into custody.
- Yu Hiong made an ante mortem declaration (Exhibit E) identifying his attackers shortly after the stabbing, and another declaration (Exhibit K) while hospitalized.
Admissibility of Evidence
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