Case Summary (G.R. No. 169004)
Charges and Initial Proceedings
Both Noynay and Ruiz were charged with assassination, specified in the legal framework as a premeditated and treacherous attack on Arriesgado, resulting in his immediate death. Following the trial, Judge Fortunato Borromeo Veloso found them guilty of homicide, citing mitigating circumstances and consequently imposed a sentence of eight years and one day of reclusion temporal, alongside an indemnity of ₱500 for Arriesgado's heirs.
Appeal and Assertions of Error
The appellant, Buenaventura Ruiz, subsequently appealed, challenging the trial court’s decision. His attorney raised several key points of error: (1) the claim that the evidence did not conclusively establish Ruiz's guilt beyond reasonable doubt; (2) the assertion that the preponderance of evidence favored his innocence; and (3) the argument for an outright acquittal based on reasonable doubt regarding his involvement.
Factual Background of the Incident
The incident transpired when Arriesgado discovered that Noynay's carabao had been damaging his sugar cane crop. Upon confronting Noynay to demand payment, a verbal altercation ensued. When Arriesgado threatened to report the matter to the barrio lieutenant, Noynay armed himself with a spear and, along with Ruiz, pursued Arriesgado. The pursuit led to an altercation, during which evidence indicated that both defendants attacked Arriesgado, resulting in fatal wounds.
Evidence and Testimonies
Eyewitness testimonies played a significant role in the proceedings. Jose Arriesgado, the deceased's son, testified to witnessing the stabbing of his father. Additionally, other witnesses, including Rosa Malinao, the wife of the deceased, also supported the claims against Ruiz and Noynay, affirming that they had fled the scene immediately after the attack. Significant evidence consisted of the different types of weapons used and the injuries inflicted upon the deceased.
Ruiz's Defense and Alibi
Ruiz attempted to assert an alibi, claiming he was in a cockpit seven kilometers away at the time of the crime. However, testimonies from witnesses contradicted this claim, establishing that Ruiz was indeed seen near the scene of the murder around the time it occurred. The trial judge found that the evidence overwhelmingly indicated Ruiz's involvement and participation in the crime.
Determination of Mitigating Circumstances
The trial court initially recognized mitigating circumstances for the defendants, specifically that of provocation and obfuscation. However, the appellate cour
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Case Overview
- The case involves the defendants Martin Noynay and Buenaventura Ruiz charged with the crime of asesinato (murder).
- The crime took place on or about August 28, 1932, in Medellin, Cebu, Philippines.
- The deceased, Silvestre Arriesgado, was killed by the defendants with premeditated intent and treachery.
Judicial Findings
- The lower court, presided by Judge Fortunato Borromeo Veloso, found the defendants guilty of homicide.
- The court recognized mitigating circumstances under Article 13 of the Revised Penal Code.
- Each defendant was sentenced to eight years and one day of reclusion temporal, ordered to indemnify the deceased's heirs in the amount of P500, and to pay costs.
Appellant's Claims of Error
- Buenaventura Ruiz appealed the decision, asserting three main errors:
- Error of Proof: The lower court erred in not declaring that the evidence did not establish Ruiz's guilt beyond reasonable doubt.
- Preponderance of Evidence: The court failed to recognize that the preponderance of evidence favored Ruiz, warranting his acquittal due to reasonable doubt.
- Absence of Acquittal: The court erred by not acquitting Ruiz outright.