Case Summary (G.R. No. 188464)
Charge and Legal Basis
Pascual was charged with murder under Article 248 of the Revised Penal Code, which penalizes the unlawful killing of another with specific aggravating circumstances. The Information accused Pascual and an unidentified accomplice of conspiring to murder Dr. Picio on March 14, 1995.
Arraignment and Prosecution Evidence
Upon arraignment on July 13, 1995, Pascual entered a plea of "Not guilty." The prosecution presented evidence indicating that Dr. Picio was shot multiple times by unidentified assailants while outside the home of midwife Marissa Robles, who was an eyewitness to the event. Marissa testified that she recognized the assailants due to the lighting conditions at the scene.
Defense and Alibi
Pascual maintained his innocence, claiming he was at home with neighbors during the time of the murder. Defense witnesses corroborated his alibi, stating they were present at Pascual's residence from 7:00 PM to 10:00 PM on the night of the crime. Despite this, the trial court found the defense unconvincing.
Eyewitness Testimony and Identification
Marissa Robles's testimony was pivotal to the prosecution's case. She identified Pascual as one of the assailants shortly after the crime, citing distinct physical features. The court affirmed the reliability of her testimony, emphasizing that a single credible witness could substantiate a murder conviction.
Evidence of Treachery
The trial court concluded that treachery was present in the commission of the murder, as Dr. Picio was caught off guard and was unable to defend himself. The court dismissed defensive arguments regarding the assault's suddenness, affirming that forewarning does not negate the existence of treachery.
Issue of Paraffin Test
Pascual's defense argued that the negative results of a paraffin test conducted on his hands should exonerate him. However, the court explained that such a test's results are not definitive proof of innocence, as external factors can affect the presence of gunpowder residue.
Verdict and Sentencing
Ultimately, the trial court found Pascual guilty beyond a reasonable doubt and imposed the penalty of reclusion perpetua along with civil damages to the victim's heirs. The decision was based on the sufficiency of evidence presented, including the eyewitness account, and the established presence of treachery.
Appeal and Findings
On appeal, Pascual raised sever
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Case Overview
- The case involves an appeal from the Regional Trial Court of Roxas, Isabela, which found appellant Pedro R. Pascual guilty of murder in connection with the killing of Dr. Maximino P. Picio, Jr.
- The decision was rendered in Criminal Case No. Br. 23-636 on April 28, 2000.
Charges and Initial Proceedings
- Appellant Pedro R. Pascual, along with an unidentified accomplice, was charged under Article 248 of the Revised Penal Code for the murder of Dr. Picio on March 14, 1995.
- Pascual was arraigned on July 13, 1995, and pleaded "Not guilty".
Incident Description
- The victim, Dr. Maximino P. Picio, Jr., was the Municipal Health Officer of San Manuel, Isabela.
- On the night of the incident, Dr. Picio was visiting Marissa Robles, a former midwife, to discuss matters related to the Rural Health Unit.
- After the meeting, as Dr. Picio was about to leave, two armed men approached him. Despite Marissa's warning, the assailants attacked and shot Dr. Picio multiple times, resulting in his death.
Eyewitness Testimony
- Marissa Robles, who was present during the shooting, identified Pedro Pascual as one of the assailants.
- The eyewitness account was supported by the lighting conditions of the scene, which included electric lights and moonlight, allowing her to recognize the assailants.
- Marissa testified that she had previously seen Pascual in the Rural Health Unit a week prior to the shooting.
Victim's Autopsy
- Dr. Bernardo Layugan conducted a post-mortem examination, confirming that