Case Summary (G.R. No. 144343)
Charges and Pleas
An Information was filed against the appellants charging them with murder under Article 248 of the Revised Penal Code, with allegations that they acted with treachery and abuse of superior strength. The appellants entered a plea of not guilty, leading to a trial.
The Case for the Prosecution
Witnesses testified that Anthony Cruz, along with his friends, encountered the appellants and their group in front of Rizal High School. Initially, an altercation ensued, leading Anthony and his friends to flee. Anthony was eventually cornered and stabbed in the back by Parreno, leading to his immediate death. Eyewitnesses Simplicio Genova, Jr. and Frederick Sabangan provided detailed accounts of the attack, identifying the appellants as the perpetrators.
The Case for the Appellants
The appellants presented alibis, asserting lack of involvement in the crime. Quindo claimed that Julius Sorongon was the actual assailant, while asserting that they were simply present at the scene. They also raised questions about the reliability of the identification made by prosecution witnesses, emphasizing the conditions of visibility and suggesting inconsistencies in testimonies.
The Trial Court’s Findings
The trial court found both appellants guilty beyond reasonable doubt of murder, qualifying the crime with treachery due to the method of attack which offered the victim no chance to defend himself. The court ruled that the physical disparity (number and weaponry) contributed to the offense being committed with abuse of superior strength, although this was absorbed under the circumstances of treachery.
The Appeal
On appeal, the appellants contested the trial court’s findings on the appreciation of treachery and abuse of superior strength. They argued that mere numerical superiority did not equate to abuse and highlighted issues concerning the evidence of blood on Parreno's clothing, as well as questioned the integrity of witness identifications.
The Court's Ruling
The appellate court affirmed the trial court’s decision, bolstering the credibility of the prosecution witnesses who positively identified the appellants. It emphasized that the characteristics of treachery were met due to the unarmed nature of the victim and the suddenness of the attack. The court dismissed the defense’s claims that conditions negated credibility and underscored the weight of the eyewitness accounts, which were
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Case Background
- This case is an appeal from the decision of the Regional Trial Court of Pasig City, Branch 156, in Criminal Case No. 113331-H.
- The appellants, Ricson Parreno and Delbert Quindo, were convicted of murder under Article 248 of the Revised Penal Code.
- They were sentenced to reclusion perpetua and ordered to indemnify the heirs of the victim, Anthony Cruz, P 50,000.00, along with P 25,000.00 as actual damages and costs of the suit.
Facts of the Case
- The charge against the appellants stemmed from an incident on November 2, 1997, where they, along with four unidentified individuals, allegedly conspired to stab Anthony Cruz.
- Anthony Cruz was a 30-year-old electrical engineering graduate, employed as a cashier, and residing with his sister in Pasig City.
- On the night of the incident, Cruz was out with friends, intending to buy food, when they encountered the group of the appellants.
- Appellant Quindo challenged the group, leading to a confrontation. Despite initially attempting to avoid conflict, Cruz and his friends were pursued by the appellants.
- Cruz was ultimately cornered and stabbed in the back by Parreno, leading to his immediate death.
Case for the Prosecution
- Witnesses, including friends of the victim, testified about the events leading up to the stabbing.
- Simplicio Genova Jr. and Frederick Sabangan identified the appellants as the assailants.
- Testimonies revealed that the victim was unarmed and caught off-guard during the attack.
- An autopsy performed by Dr. Emmanuel Aranas confirmed the cause of death to be a stab wound inflicted at the left lumbar region, penetrating vital organs.
- The victim's sister testified to the funeral