Case Summary (G.R. No. 93055-56)
Charges and Sentences
The accused-appellants were charged with murder (for the death of Andrew Angelo) and attempted murder (against Erolando Toledo). The Regional Trial Court sentenced Mancio and Yero to reclusion perpetua and ordered them to jointly indemnify the heirs of the victim the sum of P50,000.00 for moral damages. Additionally, they were sentenced to eight years of imprisonment in a separate criminal case, along with the costs of the suit.
Proceedings and Evidence Presented
During the trial, the prosecution presented nine witnesses who provided corroborative testimonies. These witnesses recounted the events following a party on the night of February 12, 1983, where Angelo and Toledo were assaulted by five individuals, including Mancio and Yero. After the party, as Angelo sought to meet a companion, he and his group encountered the assailants. The altercation resulted in Angelo being fatally stabbed and Toledo being wounded.
Testimony of Witnesses
Witnesses described a surprise attack led by Mancio, who stabbed Angelo while holding him, and Yero, who hacked at Toledo with a bolo. Further violence ensued, with Richard Doe and Roro Estrera also participating in the assault. Despite Angelo being transported to multiple hospitals for treatment, he succumbed to his injuries on February 16, 1983. Prior to his death, Angelo identified Mancio and Yero as his attackers, an identification made while under severe distress.
Defense Strategy
Mancio and Yero presented alibi defenses, claiming they were elsewhere during the crime. Mancio purported to have been at a hospital with another victim while Yero claimed he was asleep at home. Both defendants attempted to undermine the prosecution's evidence by contesting the reliability of witness testimonies but did not demonstrate that it would have been physically impossible for them to be present at the crime scene.
Analysis of Credibility of Witnesses
The court emphasized the reliability of the victims' and bystanders' testimonies, noting their proximity to the event and lack of motive to fabricate their accounts. Stemming from the observations of the trial court, the identification of the accused by witnesses was deemed credible, supported by the well-lit conditions of the crime scene and the immediacy of the witnesses’ observations.
Dying Declaration
The court considered Angelo's dying declaration, which is admissible under Section 31, Rule 130 of the Rules of Court concerning declarations made in anticipation of death. This declaration significantly contributed to establishing the identity of
...continue readingCase Syllabus (G.R. No. 93055-56)
Case Background
- This case involves the crimes of murder and attempted murder, stemming from an incident on February 13, 1983, resulting in the death of Certified Public Accountant Andrew Angelo and injuries to Erolando Toledo.
- The accused-appellants include Roldan Mancio y Salveron, Rolando C. Yero, Edgar David, Borong Estrera, and Richard Doe.
- Roldan Mancio and Rolando Yero pleaded not guilty upon arraignment; the other three accused were not in custody.
- The trial court sentenced the two convicted appellants to Reclusion Perpetua, ordered them to indemnify the victim's heirs P50,000.00, and pay P50,000.00 for moral damages.
Factual Background of the Incident
- The incident occurred after a party at Kanlaon Construction in Bagong Silang, Caloocan City.
- At approximately 9:00 p.m. on February 12, 1983, Erolando Toledo, Andrew Angelo, and their companions attended a gathering.
- After leaving the party, Angelo returned to fetch a friend, which led to a confrontation with a group of five men.
- Andrew Angelo was immediately recognized by Roldan Mancio, who then attacked him by stabbing him while holding him by the nape.
- Rolando Yero was involved in the attack, hacking at Toledo, resulting in serious injuri