Case Summary (G.R. No. 45053)
Facts of the Case
Cecilia Lagman was charged under two criminal informations: Criminal Case No. 02-200106 for the murder of Jondel Mari Davantes Santiago and Criminal Case No. 02-200107 for the frustrated murder of Violeta Sicor y Sapitula. The prosecution established that on the day of the incident, Lagman approached and assaulted Sicor, subsequently stabbing her before turning and fatally stabbing Santiago multiple times.
Trial and Prosecution Evidence
During the trial, witnesses presented by the prosecution included Donna Maniego, Violeta Sicor, and two police officers. Maniego testified that she witnessed Lagman attack Sicor and stab Santiago. Despite the lack of immediate aid from the barangay hall, she attempted to seek help for Santiago but found him fatally injured. Sicor corroborated Maniego’s account, and the police provided evidence regarding Lagman's arrest and the weapon used.
Defense's Strategy
The defense relied on denial, claiming Lagman did not stab Santiago and arguing about inconsistencies in witness testimonies, particularly focusing on Maniego's credibility and the absence of the trial judge at the witness hearings. Lagman also introduced an alibi, alleging she was attacked first, which was not corroborated by evidence.
Trial Court's Ruling
On January 18, 2008, the Regional Trial Court convicted Lagman of murder and less serious physical injuries. Lagman received a sentence of reclusion perpetua and a civil indemnity of P50,000 for the murder conviction, while she was sentenced to six months for the less serious physical injuries charge.
Appellate Proceedings
Lagman appealed, contesting the trial court's findings. However, the Court of Appeals affirmed the RTC's decision, stating that the evidence sufficiently established beyond a reasonable doubt Lagman's guilt and that the testimonies were credible and consistent, despite the different judges involved.
Issues Raised on Appeal
Lagman questioned whether the appellate court erred in establishing her guilt beyond a reasonable doubt, whether inconsistencies in witness testimonies were overlooked, and whether treachery was properly considered in the murder charge.
Supreme Court’s Analysis of Key Issues
The Supreme Court denied Lagman’s appeal but modified aspects of the ruling. The Court underscored that the prosecution clearly established the elements of murder, particularly the presence of treachery, which is defined as an attack that is sudden and leaves the victim defenseless. Eyewitness testimony was found credible, dismissing arguments regarding the trial judge's absence during witness testimonies.
Ruling on Physical Injuries Charge
The Supreme Court modified the ruling regarding the less serious physical injuries charge, stating there was insufficient evidence to support the original conviction. Instead, the court found that the injuries did not meet the criteria for less serious physical injuries under the Revised Penal Code.
Modif
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Case Background
- This case involves an appeal from the Decision of the Court of Appeals (CA) dated May 14, 2010, which upheld the Regional Trial Court (RTC) ruling on January 18, 2008.
- The RTC convicted Cecilia Lagman of Murder (Criminal Case No. 02-200106) and Less Serious Physical Injuries (Criminal Case No. 02-200107).
Facts of the Case
- Two Informations were filed against Cecilia Lagman:
- Criminal Case No. 02-200106: Charged with the murder of Jondel Mari Davantes Santiago on February 24, 2002, in Manila. The accusation specified willful and unlawful intent to kill with treachery and evident premeditation, resulting in fatal stab wounds.
- Criminal Case No. 02-200107: Charged with frustrated murder against Violeta Sicor y Sapitula, who was stabbed but survived due to timely medical assistance.
- During her arraignment, Lagman entered a negative plea to both charges.
- The prosecution's case relied on the testimonies of key witnesses including Donna Maniego, Violeta Sicor, and Police Officers.
Prosecution's Evidence
- Donna Maniego: Witnessed the initial attack on her and her mother. She testified that after being punched by Lagman, she saw Lagman stab Santiago multiple times without warning and then flee the scene.
- Violeta Sicor: Confirmed Maniego's account of the stabbing and her own injury from Lagman.
- Police Officers: Testified about the arrest of Lagman and the recovery of the weapon used in the stabbing.
Defense's Position
- Lagman denied the charges, claiming she was attacked first by Santiago and only slapped Maniego after an argument regarding rumors about her mental health.
- The defense presented Dr. Mario Lato, who treated Lagman for injuries purportedly inflicted by Santiago.
Ruling of the Trial Court
- On January 18, 2008, the RTC found Lagman guilty of Murder and sentenced her to reclusion perpetua, alongside a civil indemnity payment to Santiago's heirs.
- For the charge of Less Serious Physical Injuries, Lagman was sentenced to six months