Case Summary (G.R. No. 120956)
Charges and Proceedings
The Morenos were charged with murder, specifically alleging conspiracy and qualifying circumstances of treachery, evident premeditation, and abuse of superior strength. During the trial, while all accused were arraigned, Marcos Moreno escaped detention and was tried in absentia. Domingo claimed self-defense for his actions, while the other accused invoked alibi.
Background of the Incident
On the evening of August 5, 1989, the Morenos and the Balauros engaged in a drinking spree. Trouble began when Consuelo Moreno accused Leonardo Balauro of sexually molesting her. Domingo responded to his wife's call for help, leading to a fight between him and Leonardo. Following the initial conflict, Domingo and his children armed themselves and set out to confront Leonardo at his home.
Nature of the Crime
The evidence presented indicated that upon reaching the Balauro residence, the Morenos attacked Leonardo. Dr. Victorino Q. Araña, Medico-Legal Officer, noted multiple injuries inflicted on Leonardo, including stab and hacking wounds, confirming the violent nature of the attack.
Trial Court's Decision
On April 30, 1991, the Regional Trial Court of Mauban, Quezon, found Domingo, Felix, Roberto, and Marcos guilty of murder, rejecting the self-defense claim and alibis, concluding that the crime was committed with treachery and evident premeditation. The court sentenced Domingo and Felix to 17 years and 4 months to 20 years of reclusion temporal, while Roberto and Marcos received a lower sentence due to mitigating circumstances. Consuelo and Angel were acquitted.
Court of Appeals Review
The Court of Appeals upheld the conviction but altered the qualifying circumstance from treachery and evident premeditation to abuse of superior strength. The penalty for Domingo and Felix was changed to reclusion perpetua due to the severity of the crime.
Evaluation of Evidence
The Supreme Court emphasized the weak alibi presented by the accused. Multiple inconsistencies in the testimonies of Felix, Roberto, and Angel indicated attempts to correlate their accounts. Testimonies failed to establish credible timelines and evidence, reinforcing the prosecution's case.
Legal Interpretation of Qualifying Circumstances
The Court agreed that evident premeditation was not established due to the lack of proof concerning planning or deliberation prior to the attack. Similarly, the Court rejected the finding of treachery, noting that the Morenos announced their intentions rather than attacking unexpectedly.
Final Verdict by the Supreme Court
The Supreme Court affirmed the Court of Appeals' conviction of the accused. It modified the pen
...continue readingCase Syllabus (G.R. No. 120956)
Case Overview
- The case involves the accused, Domingo Moreno, his wife Consuelo, and their children Felix, Roberto, Marcos, and Angel, charged with the murder of Leonardo Balauro on August 6, 1989, in Sitio Seoli, Bgy. San Jose, Mauban, Quezon.
- Marcos Moreno escaped after arraignment and was tried in absentia.
- Domingo Moreno admitted to hacking the victim but claimed self-defense; Felix, Roberto, and Marcos presented alibis, while Consuelo and Angel admitted their presence but denied participation.
Facts of the Case
- The incident arose from a drinking spree involving the Morenos and the Balauros, which began on the evening of August 5, 1989, and continued into the early morning of August 6, 1989.
- A confrontation occurred when Consuelo shouted for help after an inebriated Leonardo Balauro bumped into her, leading Domingo to engage in a fight with Leonardo.
- Following the fight, Domingo and his children armed themselves and proceeded to the Balauro residence, where they attacked Leonardo, leading to his death.
Evidence Presented
- Medical evidence indicated that Leonardo sustained multiple injuries, including stab wounds, hacking wounds, incised wounds, and lacerations.
- Prosecution witnesses, including Erlina Balauro, testified to positively identify the accused as the attackers.
- The trial court rejected the alibis of the accused, fi