Case Summary (G.R. No. 141296)
Applicable Law
The applicable legal framework for this case is defined by the Revised Penal Code of the Philippines and relevant jurisprudence concerning murder, especially the qualifying circumstance of treachery as well as the credibility of witness testimony.
Case Overview
The prosecution charged Estanislaw Jaberto and Melvin Timtim with murder, alleging that they conspired to stab Primitivo Dagoc in a swift and unprovoked attack. While Timtim remains unaccounted for, Jaberto pleaded not guilty and was the singular focus of the trial.
Evidence for the Prosecution
Eyewitness accounts presented by Mardonio Pelonio and Franklin Dagoc, the latter being the son of the victim, formed the crux of the prosecution's case. They testified that Jaberto and Timtim ambushed Dagoc while he was napping outside his store, with Jaberto delivering the fatal stab. Following the attack, the witnesses pursued the assailants, leading to Jaberto's capture and the recovery of the knife used in the crime. At the police station, Jaberto confessed to owning the knife and admitted to stabbing Dagoc.
Evidence for the Defense
Jaberto's defense contended that he was merely present at the scene and did not participate in the stabbing. He claimed he was unaware of Timtim's actions and asserted that he was coerced into confessing during police questioning, which he alleged was not conducted in his presence of a lawyer. The defense also sought to depict discrepancies between witness statements and their affidavits as proof of their unreliability.
Ruling of the Trial Court
The trial court ruled that the testimonies of the prosecution witnesses were credible, clear, and convincing. The court rejected Jaberto's claim of passive presence, emphasizing his immediate flight after the incident as indicative of guilt. Furthermore, the court found that treachery was undeniably present in the manner of attack against an unsuspecting victim.
Assignment of Errors
In his appeal, Jaberto asserted two main errors by the trial court: (1) the credibility of prosecution witnesses was flawed due to inconsistencies in their accounts and (2) the conclusion that treachery characterized the murder was erroneous. Jaberto argued that the attack lacked suddenness and was not executed with malice.
The Court's Ruling on Appeal
The Supreme Court found the appeal unmeritorious. It ruled that alleged irregularities raised by Jaberto, including his detention and incomplete pre-trial procedures, were irrelevant to the determination of guilt. The Court reaffirmed the trial court's findings regarding the credibility of the eyewitnesses, asserting that the discrepancies cited by the appellant were insignificant and did not undermine their overall reliability.
Ruling on Treachery
The Court supported the trial court's classification of the crime as murder due to treach
...continue readingCase Syllabus (G.R. No. 141296)
Case Overview
- Case Citation: 366 Phil. 556
- Court: Supreme Court of the Philippines, Third Division
- Date of Decision: May 12, 1999
- Appellant: Estanislaw Jaberto y Teloy
- Co-accused: Melvin Timtim (at large)
- Charges: Murder
- Trial Court: Regional Trial Court of Cebu City, Branch 14
- Penalty Imposed: Reclusion perpetua and P50,000.00 as death indemnity
Facts of the Case
Incident Date: December 24, 1995, around 10:30 PM
Location: Lincoln Street, Cebu City
Victim: Primitivo Dagoc y Nestal
Prosecution Evidence:
- Witnesses Mardonio Pelonio and Franklin Dagoc (the victim's son) were present during the incident.
- Witnesses observed Jaberto and Timtim attack the victim, who was napping outside his store.
- Jaberto stabbed the victim in the chest with a kitchen knife.
- Witnesses pursued the assailants; barangay tanods eventually apprehended Jaberto.
- Jaberto admitted to owning the knife and stabbing the victim during police investigation.
- The victim died from the stab wound to the chest.
Defense Evidence:
- Jaberto claimed he was with Melvin Timtim and did not see the stabbing.
- He alleged coercion during police questioning and denied having stabbed the victim.
- Jaberto stated he was not assisted by a lawyer during the investigation and was beaten prior to interrogation.
Ruling of the Trial Court
- Conviction: Jaberto found guilty beyond reasonable doubt of murder.
- Key Findings:
- The trial court found