Case Summary (G.R. No. 135457)
Charges and Trial Proceedings
The prosecution charged Jose Patriarca, Jr. with murder, specifically for the killing of Alfredo Arevalo. He was also charged with murder in connection with two other individuals, Rudy de Borja and Elmer Cadag, leading to his arraignment on November 25, 1993. During the trial, evidence centered around the testimony of Nonito Malto, who recounted the events leading up to the shooting, and Elisa Arevalo, who provided details of her son’s abduction and subsequent death. The Regional Trial Court in Sorsogon found Patriarca guilty of murder and sentenced him to reclusion perpetua on January 20, 1998, while acquitting him of charges related to de Borja and Cadag due to lack of evidence.
Defense Argument
Patriarca’s defense acknowledged his membership in the New People’s Army (NPA) but denied involvement in the crimes charged. He argued that the trial court erred in convicting him of murder of Alfredo Arevalo, framing his actions as being in line with political activities linked to rebellion. This appeal primarily focused on the assertion that the offenses were committed in furtherance of rebellion.
Grant of Amnesty
In light of his claims of political motivation behind his actions, Jose Patriarca, Jr. applied for amnesty under Proclamation No. 724, which was granted by the National Amnesty Board on October 22, 1999. This grant recognized that his actions were pursued in furtherance of his political beliefs and effectively removed the legal consequences of the crimes he had been accused of.
Legal Implications of Amnesty
The legal framework for amnesty indicates that it absolves individuals from the penalties associated with their offenses, as defined under the Revised Penal Code. Specifically, it extinguishes criminal liability and the burden of consequences arising from the criminal acts, aligning the individual as though no crime had been committed. This contrasts with pardon, which is a private act restoring rights but does not negate the offense itself.
Court Decision
The Supreme Court of the Philippines, upon reviewing the case, emphasized t
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Case Overview
- The case involves accused-appellant Jose Patriarca, Jr., who is also known by the aliases "Ka Django," "Carlos Narra," and "Ka Jessie."
- He appeals the decision rendered by the Regional Trial Court in Sorsogon, Branch 52, which convicted him of murder and sentenced him to reclusion perpetua.
- The case was formally titled "People of the Philippines versus Jose Patriarca, Jr. alias 'Ka Django,' 'Carlos Narra,' 'Ka Jessie,' and 21 John Does," under Criminal Case No. 2773.
Background of the Case
- An information for murder was filed against Patriarca on August 16, 1990, regarding the killing of Alfredo Arevalo on June 30, 1987.
- The information detailed that Patriarca, along with ten armed companions, forcibly took Alfredo Arevalo from his residence and subsequently shot him with intent to kill, demonstrating treachery and evident premeditation.
- Alongside this case, Patriarca was also involved in two other murder cases concerning the deaths of Rudy de Borja and Elmer Cadag.
Trial Proceedings
- The accused was arraigned on November 25, 1993, and pleaded not guilty to the charges with the assistance of counsel.
- A joint trial was conducted for the three cases due to the substantial similarity in the facts and circumstances surrounding them.
- Key testimonies included:
- Nonito Malto, a prosecution witness, testified th