Case Summary (G.R. No. 132392)
Charge and Court Proceedings
Cesar was charged with murder under Article 248 of the Revised Penal Code through an Information filed on October 11, 1996. The trial commenced after Cesar pleaded not guilty. On January 7, 1998, the trial court found Cesar guilty beyond a reasonable doubt and sentenced him to death, ordering compensation of P51,000.00 in actual damages and P50,000.00 in moral damages to be paid to the victim's heirs.
Prosecution's Evidence
Evidence presented by the prosecution included testimony from Fernando Marcos, Jr., who witnessed the attack on Virgilio at around noon. Fernando observed Cesar, armed with a bolo, attack Virgilio from behind while he was stooping near an artesian well. Following the assault, the victim was observed with multiple hacking wounds, leading to his death due to hemorrhage as confirmed by the testimony of Dr. Genaro Merino, who conducted the post-mortem examination.
Defense's Claims
Cesar provided a differing account, alleging that Virgilio had attacked him with a bolo first, instigating a struggle that resulted in Virgilio accidentally injuring himself. He claimed that after the event, he did not resist when the police detained him.
Key Legal Issues
The primary issue on appeal was whether the trial court correctly imposed the death penalty. Cesar contended that the prosecution failed to prove evident premeditation, thus warranting a lesser punishment of reclusion perpetua. The Solicitor General contended that Cesar’s familial relationship with the victim and the qualifying circumstance of treachery justified the death penalty.
Analysis of Treachery and Premeditation
The Supreme Court found that treachery was evidently established by Cecil's sudden and unprovoked attack on an unsuspecting victim. Treachery was confirmed through Fernando's testimony, which detailed the attack's circumstances that ensured Virgilio had no chance for self-defense. However, the prosecution failed to establish evident premeditation, which the trial court also did not appreciate in its ruling.
Relationship as an Aggravating Circumstance
The familial relationship between Cesar and Virgilio was considered an aggravating circumstance, as recognized in Article 14 of the Revised Penal Code, which pertains to crimes against persons. Since the victim was Cesar's brother, the aggravating nature of this relationship was deemed correctly acknowledged in determining penalties.
Mitigating Circumstance of Voluntary Surrender
The court identified a potential mitigating circumstance related to Cesar's voluntary surrender. The requirements for voluntary surrender were met, as evidenced by police certification and unrefuted testimony; however, the trial court did not consider this in sentencing. Given the interplay of aggravating and mitigating circumstances, the penalty ultimatel
...continue readingCase Syllabus (G.R. No. 132392)
Case Overview
- The case involves an automatic review by the Supreme Court of the Philippines concerning a decision made by the Regional Trial Court of Burgos, Pangasinan.
- The accused, Cesar Marcos y Mon, was found guilty beyond reasonable doubt of the crime of murder and was sentenced to death.
- The incident occurred on August 19, 1996, involving the accused and his elder brother, Virgilio Marcos y Mon.
Charges and Initial Proceedings
- An Information dated October 11, 1996, charged Cesar with murder under Article 248 of the Revised Penal Code.
- The crime was described as having occurred with intent to kill, treachery, and evident premeditation.
- During the arraignment, the accused pleaded not guilty, and the trial commenced.
Facts of the Case
- On the day of the incident, Fernando Marcos Jr., a nephew of the accused and victim, witnessed the attack.
- Cesar attacked Virgilio from behind with a bolo, inflicting multiple fatal wounds.
- Despite Virgilio's pleas for help, Fernando could do nothing but watch.
- Following the attack, Cesar was seen seated with the bloody bolo and surrendered to the police without resistance.
Testimonies and Evidence
- Prosecution Evidence:
- Fernando Marcos Jr. testified as an eyewitness, detailing how Cesar attacked Virgilio from behind while the latter was unarmed and unaware.
- Dr. Genaro Merino conducted a post-mortem examination, confirming that the cause of death w