Case Summary (G.R. No. 219848)
Charges and Sentencing
The RTC, on October 16, 2013, found Macaraig guilty of murder, sentencing him to reclusion perpetua and imposing civil liabilities that included PhP75,000 as civil indemnity, PhP50,000 as moral damages, PhP16,750 as actual damages, and PhP30,000 as exemplary damages. The CA affirmed this ruling on November 20, 2014.
The Prosecution’s Version
The prosecution's case was built upon the testimony of several witnesses, including Francis Losano, who recounted the events leading to Joven's stabbing. He and Joven had attended a dance party, and while returning home, they were followed by Macaraig. Witnesses testified that Macaraig approached Joven from behind, put his arm around him, and stabbed him with a bladed weapon. Joven, despite suffering critical injuries, identified Macaraig to a friend before succumbing to his wounds.
The Defense's Argument
Macaraig's defense presented him as the sole witness, asserting that he was attacked by unnamed assailants, including Joven and another person who allegedly attempted to stab him. He denied responsibility for Joven's wounds, claiming they were inflicted by someone else in the scuffle.
RTC Ruling
The RTC resolved the conflicting testimonies in favor of the prosecution, determining that the evidence overwhelmingly indicated Macaraig’s guilt in the crime of murder as he exhibited treachery—an essential element that enhanced the gravity of his actions.
CA Ruling
The CA upheld the RTC’s findings, reinforcing the conclusion that Macaraig's intent was clear and that the prosecution had successfully demonstrated his culpability beyond reasonable doubt.
Supreme Court's Analysis
The Supreme Court's review centered on the validity of Macaraig's self-defense claim. It emphasized the burden of proof lies on anyone claiming self-defense to establish the presence of unlawful aggression, reasonable necessity of the means employed for defense, and lack of provocation on their part. The Court found Macaraig’s assertions of self-defense unsubstantiated, particularly due to contradictions and vagueness in his testimony that failed to convincingly demonstrate unlawful aggression from J
...continue readingCase Syllabus (G.R. No. 219848)
Case Background
- The case involves an appeal from the decision of the Court of Appeals (CA) affirming the Regional Trial Court (RTC) ruling that found Godofredo Macaraig y Gonzales (accused-appellant) guilty of murder.
- The RTC sentenced the accused-appellant to suffer the penalty of reclusion perpetua and ordered him to pay damages to the heirs of the victim, Joven Celeste.
Charges and Information
- The accused-appellant was charged with murder under an information alleging that on May 31, 2011, in Calabanga, Camarines Sur, he assaulted and stabbed Joven Celeste with intent to kill, using a bladed instrument and with treachery.
Prosecution's Version of Events
- The prosecution presented witnesses including Francis Losano, Herson Heles, Corazon Celeste, and Dr. Daniel Tan.
- Key events included:
- The victim, Joven, was at a dance party and left with friends around midnight.
- Francis Losano observed the accused-appellant following and then attacking Joven from behind, stabbing him.
- After the attack, Joven managed to get home and inform his parents about the assailant before succumbing to his injuries on the way to the hospital.
- Dr. Tan testified that Joven sustained a severe stab wound that was fatal.
Defense's Version of Events
- The defense presented accused-appellant Godofredo Macaraig as th