Case Summary (G.R. No. 115217)
Factual Background
On the afternoon of April 12, 1989, while Amelito Banug and Evangelio Asis Jr. were returning home, they encountered the accused, Danny and Santos Paredes Jr., who were armed—Danny with a firearm and Santos Jr. with a knife. Perceiving a threat, they attempted to flee but heard gunfire behind them; upon looking back, Amelito witnessed Danny shooting Evangelio, after which Santos Jr. stabbed the fallen Evangelio. Evangelio was later found dead, having sustained four gunshot wounds and two stab wounds.
Legal Proceedings
On January 9, 1991, both Danny and Santos were charged with murder in the Regional Trial Court of Lianga, Surigao del Sur. Danny Paredes asserted an alibi, claiming he was hospitalized following an incident on April 8, 1989, where he was shot by Evangelio's father. This was corroborated by a medical certificate and a witness. The trial court acquitted Danny but found Santos Jr. guilty, sentencing him to reclusion perpetua and ordering him to indemnify Evangelio's heirs.
Santos Paredes Jr.'s Appeals
In his appeal, Santos Paredes Jr. contested his conviction, contending that he was not present at the scene of the crime and asserting his entitlement to privileged mitigating circumstances due to his age—he was only fifteen at the time of the offense. He argued the trial court's decisions regarding witness credibility and defense of alibi were flawed, particularly pointing out the inconsistency of the testimony regarding Danny's alibi.
Credibility of Witness Testimony
The court emphasized the discretion of the trial judge in evaluating witness credibility. It upheld that portions of the testimony can be deemed credible while others may be rejected. The court found no significant flaw in Amelito's testimony against Santos Jr., despite the acquittal of Danny, asserting that the trial court could reasonably have arrived at different conclusions regarding each individual's guilt based on the evidence presented.
Defense of Alibi
The defense of alibi is inherently weak, necessitating proof that not only was the accused elsewhere at the time of the crime, but that being there was physically impossible. The court noted that Santos's assertion of an alibi was not supported by such proof, as he stated that Cabacungan and Patin-ay were only three hours apart by jeep, failing to demonstrate that he could not have been at the crime scene when the incident occurred.
Mitigating Circumstances and Sentencing
Santos Paredes Jr.'s argument concerning mitigating circumstances based on his age was deemed meritorious. The court noted relevant provisions of the Revised Penal Code, which
...continue readingCase Syllabus (G.R. No. 115217)
Case Overview
- The case involves the prosecution of brothers Danny Paredes and Santos Paredes Jr. for the murder of Evangelio Asis Jr.
- The incident occurred on April 12, 1989, in Kauswagan, Cabacungan, Barobo, Surigao del Sur.
- The trial court acquitted Danny Paredes but convicted Santos Paredes Jr., sentencing him to reclusion perpetua and ordering him to indemnify the victim's heirs.
Factual Background
- At around 5:00 PM on April 12, 1989, Amelito Banug and Evangelio Asis Jr. encountered Danny and Santos Paredes Jr. who were armed—Danny with a firearm and Santos Jr. with a knife.
- Sensing danger, Amelito and Evangelio attempted to flee but were pursued.
- Amelito witnessed Danny shoot Evangelio, who then fell to the ground, after which Santos Jr. stabbed the fallen victim.
- Amelito reported the incident to Evangelio’s parents, and upon returning to the scene, they found Evangelio dead with four gunshot wounds and two stab wounds.
Proceedings and Defense
- On January 9, 1991, the brothers were charged with murder in the Regional Trial Court of Lianga, Surigao del Sur.
- Danny's defense was based on alibi, asserting he was hospitalized from April 8 to April 20, 1989, after being shot by Evangelio’s father.
- Santos Jr. also pleaded alibi but was negatively identified by Amelito as one of the assailants.
- The trial court accepted Danny's alibi, supported by medic