Case Summary (G.R. No. 136143)
Applicable Law
The 1987 Philippine Constitution governs the legal proceedings relevant to this case, with particular emphasis on the right to a speedy trial, double jeopardy, and the standards of proof in criminal cases.
Procedural History
The case arose from three Informations filed against Joel Domingo and Roel Domingo for the murder of Virgilio Dalere and Glenn Rodriguez and the attempted murder of Roque Bareng, occurring on February 26, 2005. After initial arraignment and motions to re-raffle the cases due to delays, the RTC dismissed the charges due to the prosecution's failure to present evidence. The dismissal was later reconsidered upon the prosecution's claim that witnesses had not received proper notice, leading to the case being reopened.
Summary of Evidence
The prosecution’s case relied heavily on the testimony of Roque Bareng, who alleged that Joel Domingo was one of the assailants during the shooting incident. Bareng’s account, however, had inconsistencies, particularly concerning details regarding the identities and actions of the assailants. The defense presented alibi witnesses, asserting that Domingo was attending a social dance at the time of the shootings—a claim supported by witnesses who corroborated his whereabouts.
Claims of Error
Joel Domingo's appeal centered on allegations that the CA erred by allowing his re-arrest and that his constitutional right to be free from double jeopardy was violated when the RTC granted the prosecution’s motion for reconsideration after initially dismissing the cases. Additionally, he challenged the sufficiency of the evidence presented against him.
Court's Ruling
The Supreme Court ruled that Joel Domingo was indeed deprived of his right to a speedy trial due to the unreasonable delays caused by the prosecution’s failure to present evidence and the lack of substantiated justification for these delays. The protracted nature of the trial infringed upon his constitutional rights and led to his unjustified incarceration, constituting a violation of his due process rights. The Co
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Case Background
- The case concerns an appeal by Joel Domingo, accused-appellant, under Section 13, Rule 124 of the Rules of Court from a decision dated May 31, 2012 of the Court of Appeals (CA), which affirmed the Joint Judgment rendered by the Regional Trial Court (RTC) of Laoag City.
- The RTC found Domingo guilty of two counts of Murder and one count of Attempted Murder in relation to the shooting incidents on February 26, 2005.
Facts of the Case
- Three separate Informations were filed against Joel Domingo and his co-accused, Roel Domingo, detailing the charges.
- Criminal Case No. 11741-14: Accused-appellant and Roel were charged with the Murder of Virgilio Dalere.
- Criminal Case No. 11742-14: Similar charges were filed regarding the Murder of Glenn Rodriguez.
- Criminal Case No. 11743-14: Attempted Murder of Roque Bareng was charged, as he was attacked but not hit.
- The crimes occurred in Brgy. Sta. Maria, Piddig, Ilocos Norte, involving the use of unlicensed firearms.
Procedural History
- The cases were initially raffled to RTC Branch 15 where the accused pleaded not guilty.
- A motion by the accused for the re-raffle due to delays was granted, and the cases were moved to RTC Branch 14.
- The prosecution failed to present witnesses in four scheduled sessions, leading to the cases' dismissal on February 7, 2007, due to lack of evidence.
- The prosecution filed a Motion for Reconsideration, arguing that witnesses did not receive subpoenas due to threats ag