Case Summary (G.R. No. 227982)
Applicable Law
The case is governed by the Revised Penal Code of the Philippines, particularly Article 248 concerning the definition and penalty for murder. Given that the decision date is in 1994, the 1987 Philippine Constitution serves as the basis for any constitutional considerations arising from the case.
Prosecution's Case
The prosecution's evidence primarily relied on the testimony of Rolando Dadua, an eyewitness who was present during the incident. Dadua recounted that he, along with the victim and others, were at the Navotas Fishery Port when a commotion broke out. During this altercation, the accused-appellant and another individual arrived at the scene and began assaulting him and the victim.
After enduring physical assaults, Dadua witnessed the accused-appellant shoot Eric Abante at close range, killing him instantly. In the aftermath, the accused directed additional threats towards Dadua but was interrupted by a third party. Several police officers responded to the scene but initially faced uncooperativeness from those present at the Port Security Division where the incident took place.
Defense's Case
The defense, led by the accused-appellant, argued against the prosecution by presenting an alibi. Javier claimed he was engaged in his job duties at the fish port during the time of the incident and left for home shortly before the shooting occurred upon being informed of the commotion. He contended that he was wrongly identified as the shooter and claimed the police had coached the eyewitness to select him in the lineup.
Trial Court's Findings
The trial court found Javier guilty of murder, emphasizing that the testimony of Rolando Dadua was credible and consistent. The court noted that Dadua had ample opportunity to identify the accused given his proximity during the attack and the subsequent shooting. Furthermore, it dismissed Javier's alibi as unconvincing due to the lack of empirical evidence supporting his claims and the inconsistency in his narrative.
Court of Appeals' Decision
On appeal, the Court reiterated that the evidence presented clearly established the guilt of the accused-appellant beyond a reasonable doubt. The court found that the killing was committed with treachery, noting that the victim was in a defenseless state, raising his hands in surrender when he was shot. As a result, the penalty for murder was set at reclusion perpetua, alongside civil liabilities which included indemnity for the victim's heirs.
Modification of Lower Court's Ruling
The appellate court modified the decision concerning the civil liabilities. It affi
...continue readingCase Syllabus (G.R. No. 227982)
Case Overview
- Title: The People of the Philippines vs. Valtony Javier y Javelosa
- Court: Second Division
- Case Number: G.R. No. 104729
- Date of Decision: February 3, 1994
- Judges: Puno, J., Narvasa, C.J., Padilla, Regalado, Nocon (on leave)
Facts of the Case
- On December 6, 1990, Valtony Javier was charged with murder for the alleged killing of Eric Abante on December 3, 1990, in Navotas, Metro Manila.
- The indictment specified that Javier, armed with a gun and with intent to kill, attacked Abante, resulting in fatal gunshot wounds.
- Prosecution witness Rolando Dadua testified that he, Abante, and others were at Navotas Fishery Port on the night of the incident.
- A commotion broke out between Reynaldo Garcia and Dennis Garcia, leading to police involvement.
- Following the disturbance, Javier and Ponciano Enderina, identifying themselves as officers, began to assault both Dadua and Abante.
- Javier later shot Abante at close range after Abante pleaded for his life, stating, "I will kill you."
Testimonies and Evidence
Rolando Dadua's Testimony:
- Described the events leading to Abante’s death.
- Identified Javier as the assailant both in court and during a police line-up.
- Witnessed Javier's verbal threats before the shooting and noted the clear circumstances of the attack.
Additional Witnesses:
- Bienvenido Cruz corroborated Dadua’s account, observing the events from a distance.
- Cruz noted Abante’s plea of innocence and saw Javier shoot him.
Defendant's Testimony:
- Javier denied the charges, claiming he was a