Case Summary (G.R. No. 218581)
Applicable Law
- The decision primarily hinges on the 1987 Philippine Constitution and relevant provisions in the Revised Penal Code concerning homicide and physical injuries.
Factual Background
Two informations were filed against Lumahang, accusing him of murder for the killing of Velitario and slight physical injuries for stabbing Pornelos. The initial incident occurred on December 14, 2008, during a wake when Lumahang, allegedly enraged, attacked Pornelos from behind and then turned on Velitario, inflicting multiple stab wounds leading to Velitario's death. Pornelos sustained a non-fatal stab wound requiring a week of treatment.
Prosecution's Version
The prosecution presented eyewitness testimony from Alberto Poraso, who testified about witnessing the attacks. Poraso asserted that Lumahang approached Pornelos and stabbed him before swiftly turning to stab Velitario multiple times. Medical examinations confirmed the severity of Velitario's injuries, which ultimately led to his death.
Defense's Version
Lumahang's defense was centered on self-defense and defense of relative claims. He alleged that he was merely defending his cousin LL against harassment from a group, which resulted in a physical altercation. He denied any intent to kill and claimed he was attacked first, sustaining injuries in the process.
Ruling of the RTC
The RTC convicted Lumahang for murder and less serious physical injuries based primarily on Poraso's testimony, which it found credible. The court emphasized the unexpected and sudden nature of the attacks, qualifying them under the circumstances of treachery, particularly for Velitario's murder.
Ruling of the CA
The CA affirmed the RTC's decision while modifying Lumahang's conviction for the injuries inflicted on Pornelos to slight physical injuries, citing the lack of intent to kill as inferred from the nature of the injuries.
Issues Raised
- Whether the CA erred in convicting Lumahang despite the prosecution's failure to prove his guilt beyond a reasonable doubt.
- Whether the CA erred in appreciating the qualifying circumstance of treachery in the attack on Velitario.
Supreme Court's Ruling
The Court partially granted Lumahang's appeal, affirming his conviction for homicide instead of murder, determining that the qualifying circumstance of treachery was not present in the killing of Velitario. The Court found that while the attack on Pornelos demonstrated treachery, the attack on Velitario was more frontal and did not meet the threshold of treachery since Velitario could have perceived the danger and had an opportunity to flee.
Clarification on Guilt
The Court upheld the CA's findings regarding the weight of the prosecution's evidence, emphasizing the credibility of eyewitness testimony over Lumahang's defense, which it deemed weak and unsubstantiated.
Examination of Treachery
The Court critiqued the CA's rationale in affirming treachery based on the suddenness of the attacks, stating that treachery requires not only suddenness but the element of ensuring that the victim cannot defend themselves. The Court concluded that Velitario's failure to react did
...continue readingCase Syllabus (G.R. No. 218581)
Case Background
- Court: Supreme Court of the Philippines
- Decision Date: March 27, 2019
- G.R. No.: 218581
- Parties Involved:
- Plaintiff-Appellee: People of the Philippines
- Accused-Appellant: Larry Lumahang y Talisay
Procedural History
- Lumahang filed an ordinary appeal assailing the Decision dated July 14, 2014, of the Court of Appeals (CA) which modified the Judgment of the Regional Trial Court (RTC) of Quezon City.
- The RTC had found Lumahang guilty beyond reasonable doubt of Murder and Slight Physical Injuries in Criminal Case Nos. Q-08-156459 and Q-08-156460.
Facts of the Case
- Two separate Informations were filed against Lumahang for:
- Criminal Case No. Q-08-156459: Stabbing Augusto Pornelos with intent to kill but resulting only in slight physical injuries.
- Criminal Case No. Q-08-156460: Stabbing Rodel Velitario multiple times, resulting in his death.
- On December 14, 2008, at a wake in Quezon City, Lumahang attacked Pornelos from behind with a knife.
- Later, he confronted Velitario, stabbing him multiple times, leading to Velitario's death as confirmed by medical examination.
Prosecution's Version
- Eyewitness Alberto Poraso testified that Lumahang, appearing furious, stabbed Pornelos in the buttocks and then repeatedly attacked Velitario.
- Medical examinations revealed that Velitario suffered fatal wounds, including two stab wounds to the abdomen, which impacted his left kidney.
Defense's Version
- Lumahang claimed he was defending his cousin from drunken bystanders who allegedly made inappropriate advances.
- He asserted he was attacked first, sustaining a stab wound to his thigh during the altercation.
- Lumahang denied stabbing anyone intentionally and stated he merely grappled for the knife.
- He was arrested after volu