Case Summary (G.R. No. 233479)
Proceedings Before the Trial Court
Jomar Doca was charged with murder in an Information dated July 3, 2007, alleging that he killed Roger Celestino with evident premeditation and treachery. Upon arraignment, Doca entered a plea of "not guilty," leading to a trial. Key witnesses for the prosecution included Rogelio Castro and Dr. Rebecca Battung, who provided testimony regarding the events leading up to the murder and the cause of death, respectively. Doca presented himself as the sole witness for the defense, claiming self-defense.
Prosecution's Version of Events
The prosecution's case hinged on the testimony of eyewitness Rogelio Castro, who recounted seeing Doca stab Celestino after an altercation. Castro and others were returning from a friend's house when they encountered Doca, who was intoxicated and seeking out Roger. As Roger approached, Doca unexpectedly stabbed him, resulting in the victim's immediate death. Additional testimonies corroborated that Doca was armed with a Rambo knife and fled the scene after the incident.
Defense's Argument
Doca argued self-defense, asserting that he was attacked by Roger first and had no choice but to retaliate with a knife. Doca claimed that he initially didn’t respond but felt compelled to defend himself when Roger brandished a fan knife. However, this defense lacked supporting evidence, as no other witnesses supported Doca’s account of unlawful aggression from Roger.
Trial Court's Ruling
In its judgment dated February 4, 2016, the trial court found Doca guilty of murder, emphasizing that he failed to prove self-defense. The court noted the presence of treachery in the manner of the attack, qualifying the act as murder. Doca received a sentence of reclusion perpetua along with monetary damages owed to the victim’s family, which included civil indemnity and moral damages.
Proceedings Before the Court of Appeals
The Court of Appeals affirmed the trial court's conviction on March 28, 2017, with modifications on the monetary awards. Doca challenged the trial court’s reliance on witness testimony and argued that his actions did not constitute treachery since the victim had indications of danger. The prosecution maintained that the attack was sudden and that Doca’s claims of self-defense were not substantiated.
Court of Appeals' Ruling
The appellate court upheld the finding of treachery due to the nature of the attack and dismissed Doca's claims of self-defense as purely self-serving. The court acknowledged that, although the trial court did not recognize voluntary surrender as a mitigating factor, it upheld the penalty of reclusion perpetua while modifying the monetary damages awarded.
The Present Appeal
Doca sought acquittal and compliance with a resolution for supplemental briefs but ultimately depended on the briefs filed in the appellate court. The central issue was whether the Court of Appeals erred in affirming his conviction for murder.
Legal Analysis and Rulings
The Supreme Court examined the definition of murder under Article 248 of the Revised Penal Code, identifying necess
...continue readingCase Syllabus (G.R. No. 233479)
Case Overview
- This case involves an appeal by Jomar Doca y Villaluna against the Decision dated March 28, 2017, of the Court of Appeals, which affirmed his conviction for murder by the trial court.
- The core issue revolves around the circumstances of the killing of Roger C. Celestino on July 1, 2007, in Solana, Cagayan, where Doca was charged with murder.
The Charge
- Jomar Doca y Villaluna was charged with murder under the Information dated July 3, 2007, for the killing of 17-year-old Roger C. Celestino.
- The charge specified that Doca attacked and stabbed Celestino with a Rambo knife, demonstrating intent to kill, evident premeditation, and treachery.
Proceedings Before the Trial Court
- The case was assigned to the Regional Trial Court - Branch 4, Tuguegarao City, where Doca pleaded "not guilty."
- The trial involved testimonies from multiple prosecution witnesses, including Rogelio Castro, Benjamin Cabisora, Dr. Rebecca Battung, SPO3 Bienimax Constantino, and PO3 Roque Binayug.
- The prosecution and defense reached a stipulation regarding actual damages resulting from the victim's death.
Prosecution's Version
- Eyewitness Rogelio Castro testified about witnessing the stabbing incident, describing Doca as drunk and angry.
- He noted that Doca was waiting for Celestino and suddenly stabbed him as he passed by, after which Doca fled the scene.
- Benjamin Cabisora corroborated Castro's account, while Dr. Rebecca Battung confirmed that Celestino died from a stab wound causing severe hemorrhage.
- Police officers testified about responding to reports of the incident and recovering the murder weapon, a Rambo knife.
Defense's Version
- Doca claimed self-defense, asserting that he was attacked by Celestino first, who boxed him repeatedly.
- He stated that he only used the fan knife (balisong) after grappling for it to defend himself when Celestino allegedly drew it against him.
- Doca surrendered to Barangay Captain Edgar Palattao the