Case Summary (G.R. No. 235316)
Incident Details
The prosecution's case was primarily based on the testimonies of two eyewitnesses, Celestino Atun and Percival Amador, alongside police accounts. Their evidence depicted a violent confrontation between Avelino and the victim, Rodrigo Aringo, where Jose Manansala physically subdued Rodrigo to facilitate the stabbing by Avelino with a balisong knife. Rodrigo sustained multiple fatal wounds, resulting in his death shortly after the incident. An autopsy confirmed the cause of death as a massive hemorrhage attributable to the injuries sustained.
Defense Arguments
The defendants sought to establish a claim of self-defense, arguing that Rodrigo was armed with a knife and had initiated the confrontation. Two witnesses for the defense—Domingo Daria and Salvador Petilos—supported this assertion, detailing an altercation that commenced with Rodrigo demanding payment for carrying Avelino's baggage. However, the claim was undermined by evidence, including the absence of any knife found with Rodrigo upon police arrival and the lack of injuries on Avelino.
Judicial Findings
The trial court found the prosecution's narrative credible, convicting both Avelino and Jose Manansala of murder. The court acknowledged Avelino's claim of provocation, given the physical assault he faced from Rodrigo, thus allowing for a mitigating circumstance in his sentencing. However, the court also highlighted the treacherous nature of the attack, as Avelino stabbed Rodrigo while the latter was restrained by Jose.
Co-Principal vs. Accomplice Liability
While Avelino was found guilty as a principal offender, Jose's culpability was debated. The court determined that Jose acted in concert with Avelino but did not conspicuously intend to kill, positioning him as an accomplice rather than a co-principal. Despite lacking clear evidence of premeditation, Jose’s actions facilitated the infliction of lethal injuries, thus substantiating his liability as an accomplice.
Sentencing
The court articulated that Avelino, due to his mitigating circumstance, should receive a penalty under the Indeterminate Sentence Law, resulting in an indeterminate sentence ranging from 10 years and 1 day of prision mayor to 17 years and 4 months of reclusion temporal. Conversely, Jos
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Case Overview
- This case involves an appeal from the decision of the Court of First Instance of Albay, where Avelino Manansala, Jr. and Jose Manansala were convicted of murder.
- The court sentenced Avelino to an indeterminate penalty ranging from 10 years and 1 day of prision mayor to 17 years, 4 months, and 1 day of reclusion temporal, while Jose received a sentence of reclusion perpetua.
- Both were ordered to jointly indemnify the heirs of the victim, Rodrigo Aringo, in the sum of P6,000.00.
Facts of the Case
- On March 27, 1962, a quarrel erupted inside the New Bicol Carinderia, located near the Legaspi Port Market in Legaspi City.
- Eyewitnesses Celestino Atun and Percival Amador testified about the events leading up to the stabbing.
- Jose Manansala was seen embracing the victim, Rodrigo, from behind, rendering him unable to defend himself as Avelino stabbed him multiple times with a balisong.
- The victim succumbed to his injuries before reaching the hospital, having sustained thirteen stab wounds.
Prosecution's Evidence
- The prosecution's case heavily relied on the testimonies of the eyewitnesses and police officers who responded to the incident.
- The police found Avelino still holding the knife used in the attack and the victim's body lying in a pool of blood.
- An autopsy confirmed that Rodrigo died from massive hemorrhage and shock due to the stab wounds.
Defense's Argument
- The defense argued for self-defense, claiming that Rodrigo was armed with a knife and had attempted to