Case Summary (G.R. No. 146364)
Factual Background
The prosecution's evidence indicates that on the night of December 3, 1981, Benito Adarlo was seated by the roadside with Frangeline Salazar holding his arm. Carlo Lagrana approached, illuminated the victim's face with a flashlight, and violently struck him on the head with a wooden stick, causing the victim to fall unconscious. The victim succumbed to his injuries on December 6, 1981, as confirmed by the autopsy, which indicated that the cause of death was "shock secondary to severe intracranial hemorrhage due to skull fracture from head trauma."
Eyewitness Testimonies
Nestor Adarlo, the victim’s brother, was present at the scene and attempted to assist his brother but was confronted by Lagrana. Another eyewitness, Pio Sigalat, corroborated the events by confirming seeing Lagrana strike the victim. Following the attack, both Lagrana and Salazar were questioned by police but were initially released. Charges of murder were filed against them, leading to a trial, where Lagrana was first tried, while Salazar faced trial later due to his arrest in 1983.
Defense and Trial Court Findings
Lagrana claimed self-defense, asserting that he was threatened by the intoxicated victim, who allegedly lunged at him with a knife. Salazar contended he was frightened by the victim’s behavior. The trial court rejected their defenses, ruling that the attack was intentional and characterized by treachery, given that Lagrana had the opportunity to strike without facing any risk from the victim’s actions.
Sentences and Financial Obligations
The trial court convicted Lagrana of murder and sentenced him to reclusion perpetua (life imprisonment) while condemning Salazar as an accomplice to an indeterminate penalty. Both were ordered to indemnify the legal heirs of Benito Adarlo, with specific amounts attributed to each accused for actual damages.
Appeal Points Raised
Lagrana appealed, acknowledging his conviction but contesting the absence of a mitigating circumstance for voluntary surrender, which he argued should have been considered. The court determined that his and Salazar's subsequent reporting t
...continue readingCase Syllabus (G.R. No. 146364)
Case Background
- The case involves the appeal of Carlo Lagrana y Manibo from the Regional Trial Court's judgment in Calapan, Oriental Mindoro, where he was convicted of Murder.
- The other accused, Frangeline Salazar, was found guilty as an accomplice but did not appeal.
- Lagrana was sentenced to reclusion perpetua (life imprisonment) and ordered to indemnify the heirs of the victim, Benito Adarlo, in the amount of P8,000.00.
Incident Overview
- The incident occurred on the evening of December 3, 1981, when the victim, Benito Adarlo, was seated near a store with Salazar.
- Salazar held Adarlo's right arm, while Lagrana, armed with a flashlight and a piece of wood (kakawati), attacked the victim.
- Lagrana struck Adarlo on the head, causing him to fall and become unconscious; he subsequently died in the hospital on December 6, 1981.
- The autopsy identified the cause of death as "shock secondary to severe intracranial hemorrhage secondary to skull fracture secondary to head trauma."
Eyewitness Accounts
- Nestor Adarlo, the victim's brother, witnessed the attack and attempted to assist his brother but was challenged by Lagrana.
- Pio Sigalat, ano