Case Summary (G.R. No. 188283)
Procedural History
An information was filed against Quimzon and three others for murder on July 28, 1992. Quimzon surrendered to authorities on August 18, 1994, was arraigned on September 28, 1994, and pleaded not guilty. The prosecution's case centered around the testimony of Emolyn Casiong, the victim’s sister, who was a crucial eyewitness to the events leading to her brother’s death.
Evidence Presented by the Prosecution
The prosecution established that on the night of the incident, while attending a dance, Marlo bumped into Quimzon, which led to a confrontation. Testimony revealed that after stepping outside the dance hall at the invitation of a female acquaintance, Marlo was attacked by Canoto and Edgardo, followed by Quimzon, who stabbed him further. Emolyn Casiong recounted that she witnessed the stabbing and attempted to get help, resulting in Marlo being taken to the hospital, where he died shortly after. Eyewitness accounts and the aggressive attack characterized by surprise and multiple assailants portrayed a coordinated attack.
Defense of Alibi
Quimzon's defense relied on an alibi, asserting he was at a different dance 18 kilometers away during the crime. He denied knowing the other accused and claimed he only learned of Marlo’s death later. This defense was supported by testimonies from witnesses affirming his presence at the distant location. However, such a defense is typically weak, especially against positive identification by eyewitnesses.
Analysis of Corpus Delicti
Quimzon contended that the prosecution failed to establish the corpus delicti, which is essential for a murder conviction. He argued that the testimony of Dr. Adelaida Asperin regarding the autopsy was hearsay, as Dr. Amparo Villanueva conducted it and was deceased before the trial. Nevertheless, the court clarified that proving the corpus delicti does not solely depend on an autopsy report but may include credible witness accounts affirming the fact of death and the wrongful act leading to it.
Credibility of Witness Testimony
It was argued that Emolyn's failure to provide an affidavit during the preliminary investigation and her delayed testimony undermined her credibility. The court, however, noted that her testimony was consistent and compelling despite minor inconsistencies, thus affirming her reliability. Emolyn explained the circumstances of her delayed appearance, including police statements regarding her ability to testify as a family member of the victim.
Findings on Treachery and Liability
The appellate court agreed that treachery was present in the killing, as Marlo was ambushed without warning, preventing him from defending himself. The court indicated that the attack's execution displayed a calculated plan by the accused that ensured the victim's death without risking their safety.
Penalt
...continue readingCase Syllabus (G.R. No. 188283)
Case Background
- This case originated from a petition for review on certiorari under Rule 45 of the Rules of Court.
- The decision under review was issued by the Regional Trial Court of Tacloban City, Branch 16, on December 17, 1997.
- The appellant, Ricky Quimzon, was found guilty of murder and sentenced to reclusion perpetua.
Information Against the Appellant
- An Information was filed on July 28, 1992, charging Ricky Quimzon and three others with murder.
- The alleged crime occurred on March 7, 1992, in Burauen, Leyte, involving a fatal attack on Marlo Casiong.
- The charges included conspiracy, treachery, and abuse of superior strength, resulting in Marlo Casiong’s death due to multiple stab wounds.
Appellant's Surrender and Arraignment
- Ricky Quimzon voluntarily surrendered to police on August 18, 1994, while his co-accused remained at large.
- He entered a plea of not guilty during his arraignment on September 28, 1994, with the assistance of legal counsel.
Prosecution's Evidence
- The prosecution established that on the night of the incident, Marlo Casiong and others were at a benefit dance.
- Following a minor altercation, Marlo was lured outside by Salvacion Lacsarom, where he was ambushed by the accused.
- Witnesses, including Marlo's sister Emolyn and Rommel RedoAa, testified to seeing the attack.
- The attack involved multiple assailants using bolos, leading to Marlo’s eventual death before reaching the hospital.
Defense Strategy
- The appellant claimed an alibi, asserting he was at a different dance 18 kilometers away at the time of the incident.
- He denied knowing his co-accused and claimed he did not stab Marlo.
- Two witnesses corroborated the appellant's alibi, but the trial court found the prosecution's evidence more compelling.