Case Summary (G.R. No. 229380)
Charges and Trial Proceedings
Alejo Obligado y Magdaraog was charged with murder in the Regional Trial Court (RTC) of Iriga, Branch 35, with the accusation detailing a premeditated and treacherous attack on the victim that resulted in death. Upon arraignment, the appellant pleaded not guilty. During the trial, eyewitness Roberto Bagaporo testified that the victim was attacked from behind by the appellant with a bolo knife, leading to fatal wounds. Police and medical testimonies corroborated the eyewitness account, establishing the appellant's culpability.
Victim's Testimony and Evidence Presented
The prosecution presented various testimonies, including that of Dr. Breandovin Saez, who conducted a post-mortem examination and confirmed that one of the wounds was fatal due to significant hemorrhage from the carotid artery. Additionally, the victim's widow provided evidence of economic loss, detailing her husband’s income and expenses related to the funeral, asserting financial impact following the murder.
Appellant's Defense
In his defense, the appellant claimed that the killing was accidental, asserting that the victim brandished a bolo knife first, which led to a struggle resulting in the victim's injury. This was supported by witness Apolinario Manaog, who claimed that the victim was the initial aggressor. However, the RTC assessed the credibility of these claims against the stronger eyewitness accounts and physical evidence.
RTC Decision and Sentencing
On February 28, 2001, the RTC ruled against the appellant, finding him guilty of murder and imposing the penalty of reclusion perpetua. The court also ordered him to pay damages, identifying the circumstances of treachery in the attack as important to the conviction. This decision was met with an appeal, leading to a review by the Court of Appeals.
Court of Appeals Review and Modifications
The appellate court affirmed the trial court's finding of guilt but modified the civil liabilities. The Court appreciated the mitigating circumstance of voluntary surrender based on the testimony of arresting officers, changing the damages awarded to the victim's heirs, particularly eliminating exemplary damages due to the interpretation of the appellant's surrender circumstances.
Final Ruling by the Supreme Court
The Supreme Court reiterated the lower courts' findings regarding the murder charge, confirming the intentional nature of the act and the absence of any meaningful opportunity for the victim to defend himself. However, the Court held that the voluntary surrender mitigating circumstance could not apply as the appellant had no genuine choice but to submit to arrest.
Damages and Financial Liability
The Court ruled on the amounts to be paid by the appellant to the v
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Case Background
- The case involves Alejo Obligado y Magdaraog, who was charged with murder in the Regional Trial Court (RTC) of Iriga, Branch 35.
- The incident occurred on March 12, 2000, at approximately 7:45 PM in Barangay de la Fe, Buhi, Camarines Sur.
- The Information filed against him detailed that he attacked Felix Oliveros y Raada with a bolo, striking him from behind, leading to the victim's death.
Charges and Plea
- Alejo Obligado y Magdaraog was charged under the Revised Penal Code for the crime of murder.
- Upon his arraignment, he pleaded not guilty to the charges levied against him.
Prosecution Evidence
- Key prosecution witness Roberto Bagaporo testified about the events leading to the murder, describing a gathering where the victim was attacked.
- Bagaporo observed the appellant grab the victim's hair and then slash his neck with a bolo, resulting in the victim falling face down.
- Senior Police Officer (SPO) Jimmy Jose confirmed the report of the incident and the victim's condition upon arrival at the scene.
- Dr. Breandovin Saez conducted a post-mortem examination, identifying two incised wounds on the victim, with the fatal wound being deep enough to sever the carotid artery.
Victim's Family Testimony
- Gloria Oliveros, the victim's widow, testified regarding her husband's earnings and presented evidence of funeral