Case Summary (G.R. No. 225745)
Relevant Dates
- The RTC decision was rendered on December 10, 2010.
- The CA decision, which modified the RTC ruling, was issued on September 24, 2015.
- The Supreme Court's final decision was rendered on February 28, 2018.
Summary of Charges
Endaya was charged with Parricide (Criminal Case No. RY2K-058) and Homicide (Criminal Case No. RY2K-059) based on the allegation that he had deliberately attacked and stabbed both Jocelyn and Marietta on November 21, 1999. The prosecution characterized the assault as premeditated and executed with treachery.
Proceedings and Evidence
During the arraignment on May 11, 2000, Endaya pleaded not guilty to the charges. The prosecution presented evidence primarily through the testimony of Jennifer de Torres, who was present during the attack and witnessed Endaya committing the stabbings. Medical records, including postmortem examinations, confirmed that both victims sustained multiple stab wounds leading to their deaths.
Defense Claim
Endaya’s defense hinged on the assertion of self-defense, claiming that he acted to protect himself from an immediate threat posed by De Torres, who he claimed attacked him. He testified that he inadvertently stabbed both victims while trying to defend himself against De Torres, who allegedly used a bolo weapon against him.
RTC Ruling
The RTC found Endaya guilty of both charges, emphasizing that his claim of self-defense was unsubstantiated. The court stated that the evidence did not support Endaya's assertion of unlawful aggression from the victims. Moreover, the court noted Endaya’s actions—inflicting multiple stab wounds—rendered his self-defense claim implausible. The RTC imposed penalties of reclusion perpetua for parricide and an indeterminate sentence for homicide, along with required civil indemnities.
CA Ruling
On reviewing the RTC’s decision, the CA upheld the finding of guilt but modified the sentence for homicide based on misapplication of the Indeterminate Sentence Law, adjusting the maximum period of imprisonment. The CA also updated the monetary awards in favor of the victims’ heirs to align with prevailing jurisprudential standards.
Supreme Court Ruling
In the Supreme Court, Endaya’s appeal was dismissed, with the Court affirming the decision of the CA. The Supreme Court reiterated the essentials for claiming self-defense and determined that Endaya did not meet the burden of proof necessary to substantiate his defense. Endaya's contradictory claims and the lack of physical evidence to support his version of events further weakened his defense.
Key Legal Principles
The resolution underscored that in a self-defense plea, the accused carries the burden to show clear and convincing evidence of unlawful aggre
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Case Information
- Court: Third Division
- G.R. No.: 225745
- Decision Date: February 28, 2018
- Case Numbers: Criminal Case Nos. RY2K-058 and RY2K-059
- Parties:
- Plaintiff-Appellee: The People of the Philippines
- Accused-Appellant: Arsenio Endaya, Jr. y Perez
Facts of the Case
- Charges:
- Endaya was charged with Parricide for the death of his wife, Jocelyn Quita-Endaya.
- Endaya was also charged with Homicide for the death of his mother-in-law, Marietta Bukal-Quita.
- Incident Details:
- On November 21, 1999, at approximately 6:30 PM in Barangay Talahiban II, San Juan, Batangas, Endaya attacked both victims armed with a bladed weapon.
- The attacks were characterized by treachery, evident premeditation, and no justifiable cause, resulting in multiple stab wounds that caused instantaneous death for both victims.
- Procedural History:
- Endaya was arraigned on May 11, 2000, and he pleaded not guilty.
- During trial, civil liabilities were stipulated, including amounts for funeral expenses, loss of income, and death indemnity.
Evidence Presented
Prosecution Evidence:
- Testimony from Jennifer de Torres, Jocelyn’s son, who witnessed the attack.
- De Torres reported hearing his mother call for help and saw Endaya stabbing her.
- Postmortem examinations confirmed multiple stab wounds on both victims.
Defense Evidence:
- Endaya admitted to the killings but claimed self-defense.
- He testified that he was attacked by de Torres with a bolo, which led him to use a knife in self-defense.
- The defense presented anatomical sketches to support claims of injuries sustained by Endaya, but these were found to be inconsistent