Case Summary (G.R. No. 176114)
Charges and Initial Proceedings
The charge against the Rodico brothers stemmed from the fatal stabbing of Dominador delos Santos, which resulted in his death due to severe injuries. Both accused pleaded not guilty upon their arraignment. Following a trial, the court on May 15, 1992, found them guilty, sentencing them to reclusion perpetua and imposing damages to be paid to the victim's heirs totaling P79,100.
Appellant's Claims
Victorio Rodico appealed the conviction, arguing that the prosecution failed to prove his guilt beyond a reasonable doubt. He enumerated three primary errors: first, that the prosecution did not sufficiently establish his guilt; second, that there was no evidence of conspiracy; and third, that he should have been acquitted due to reasonable doubt.
Prosecution's Evidence
The prosecution's case relied heavily on eyewitness testimony from several individuals, including children who were present during the incident. Key testimonies included that of Erna dela Rosa and Nilda Tuviera, who identified Marlo Rodico as the assailant and Victorio Rodico as one of the accomplices who restrained the victim. Their testimonies, corroborating the prosecution's narrative, were critical to establishing the facts surrounding the murder.
Defense's Arguments
The defense primarily rested on the assertion of innocence, with both accused denying involvement in the crime. Marlo Rodico claimed he was a passive observer during a confrontation between Victorio Rodico and the victim. Victorio asserted that he was merely a witness to the stabbing, frightened into silence by Marlo's threats which inhibited him from reporting the incident.
Court's Analysis of Eyewitness Credibility
The court evaluated the credibility of the child witnesses who provided testimony against the accused. It held that although they initially did not name Victorio Rodico directly, their subsequent identification of him as having held down the victim was credible and reliable, given the circumstances of visibility and their relative proximity to the event. The court reaffirmed that it is well-established that testimony from minors can be compelling if deemed credible.
Conspiracy and Accountability
The court addressed the argument surrounding conspiracy. Despite no explicit evidence of a prior agreement to commit the murder, the coordinated actions of the accused during the crime were sufficient to establish conspiracy. Victorio Rodico's participation in restraining the victim while Marlo Rodico inflicted the fatal stab wound demonstrated their shared intent to commit the crime.
Treachery and Aggravating Circumstances
The court noted an error in the trial court's classification of treachery as a qualifying circumstance rather than a generic aggravating circumstance, as it was not pleaded in the information but was established during the trial. The attac
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Case Background
- The case involves the Christmas-day killing of Dominador delos Santos.
- Accused-appellants Victorio Rodico and Marlo Rodico, along with an unknown assailant (John Doe), were charged on April 24, 1991.
- The incident occurred on December 25, 1990, at Barangay Poblacion, Tayug, Pangasinan.
- The charge was based on Article 248 of the Revised Penal Code, alleging willful and unlawful killing with intent to kill and using superior strength.
Initial Proceedings
- Both accused pleaded not guilty during their arraignment.
- A joint trial was conducted, leading to a decision on May 15, 1992, where both were found guilty.
- Sentencing included reclusion perpetua, payment of compensatory damages (₱50,000), moral damages (₱20,000), and actual funeral expenses (₱9,100).
Appeal and Allegations of Error
- Victorio Rodico filed an appeal, asserting three primary errors:
- The trial court erred in concluding that the prosecution proved his guilt beyond reasonable doubt.
- The court erred in finding a conspiracy justifying his conviction.
- The court erred in finding him guilty and not acquitting him based on insufficient proof.
Prosecution's Case
- The prosecution relied on testimonies from several witnesses including Nilda Tuviera, Erna dela Rosa, Teresita delos Santos, Pat. A