Case Summary (G.R. No. 101451)
Factual Background
On September 18, 1986, Menardo Garcia was attacked by the accused while walking home from school. The six accused approached Garcia and initiated a confrontation, during which Carlos Pabillar punched him and commanded the others to attack Garcia. Regalario subsequently stabbed Garcia, leading to a fatal injury. The incident unfolded in a well-lit area, and witnesses, including Romano Padillo and Glenda Osabal, identified the assailants.
Judicial Proceedings
During the trial, Regalario and Pabillar initially pleaded not guilty but later changed their pleas to guilty before the prosecution rested its case. The trial court found all accused guilty of murder under Article 248 of the Revised Penal Code and imposed a sentence of Reclusion Perpetua, along with financial obligations to the victim’s heirs.
Issues Raised on Appeal
The appellants contended that the trial court erred in rejecting their notice of appeal as it was filed late, in accepting their guilty pleas without proper explanation of the charge, and in relying primarily on the testimonies of prosecution witnesses while dismissing defense testimonies. They also claimed the trial court did not consider their minority as a mitigating circumstance.
Decision on Appeal
The appellate court affirmed the trial court's conviction. It ruled that the notice of appeal was indeed filed late and that the appellants had not raised timely objections or concerns regarding their pleas during the trial. The court further found the evidence presented by the prosecution credible and substantial, particularly emphasizing the existence of a conspiracy among the accused.
Mitigation of Penalty
While the court acknowledged the claims of minority presented by Regalario and Pabillar, it noted that the evidence did not sufficiently prove their ages to warrant mitigating circumstances. However, it recognized that Rolan
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Case Overview
- This case involves an appeal by accused-appellants Alex Regalario y Villagracia, Carlos Pabillar y Villon, Jose Quiniquito y Magnata, Rolando de Chavez y Montalbo, Augurio Villagracia, Jr. y Isabelo, and Alberto Desembrana against a judgment from the Regional Trial Court of Lucena City, Branch 58.
- The court declared the accused guilty of murder in Criminal Case No. 565, which stemmed from an incident on September 18, 1986, resulting in the death of Menardo Garcia.
- The court found that the accused, armed with deadly weapons, conspired and attacked Menardo Garcia with evident premeditation and abuse of superior strength.
Incident Details
- The attack occurred at approximately 9:00 PM, as Menardo Garcia and his companions, Glenda Osabal and Romano Padillo, were walking home from school.
- The accused confronted and chased Menardo Garcia after he was asked about a "balisong" (a folding knife) that he did not possess, leading to a physical assault.
- Menardo Garcia was outnumbered and ultimately stabbed by Alex Regalario while the other accused continued to assault him.
Arraignment and Pleas
- During the initial arraignment on October 28, 1986, all accused except Desembrana pleaded not guilty.
- Regalario and Pabillar later changed their pleas to guilty before the prosecution rested its case. Desembrana was apprehended later and pleaded not guilty.
Trial Findings
- The trial court found the accused guilty of murder under Article 248 of the Revised Penal Code, citing evident premeditation and abuse of superior strength as aggravating circumstances.
- The court sentence