Case Summary (G.R. No. 99259-60)
Conviction and Sentences
Emilio Santos was convicted of murder and frustrated murder by the Regional Trial Court of Manila, Branch XLIX. For the murder of Valentino Guevarra, he was sentenced to reclusion perpetua and ordered to pay damages to Guevarra's heirs. For the frustrated murder of Francisco Lacsa, he received an indeterminate sentence and was similarly ordered to pay damages.
Errors Assigned by Appellant
The appellant does not contest the conviction itself but argues that the trial court erred in failing to recognize two mitigating circumstances in his favor: the immediate vindication of a grave offense against his father and the privileged mitigating circumstance of incomplete defense of a relative.
Prosecution's Evidence
The prosecution's case rested on testimony from Francisco Lacsa, who detailed the violent confrontation involving the appellant, his brother, and others. The prosecution established that the appellant brutally attacked Valentino, leading to his death, and that he inflicted severe injuries on Lacsa.
Appellant's Defense
The defense claimed self-defense and argued that the appellant acted to protect his father from an assault by Lacsa and Guevarra. However, the appellant's testimony revealed inconsistencies and reliance on hearsay to justify his actions as an immediate response to aggression against his father.
Trial Court's Findings
The trial court found the prosecution's account credible and discarded the self-defense claim. It established that the elements of self-defense, especially unlawful aggression, were absent since the initial confrontation had ended by the time the appellant attacked Lacsa.
Mitigating Circumstances: Incomplete Defense of a Relative
To successfully argue incomplete defense of a relative, the appellant needed to demonstrate the existence of unlawful aggression. The Supreme Court affirmed the trial court's determination that there was a lack of proof of such aggression and therefore a failure to establish the claim.
Mitigating Circumstances: Immediate V
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Case Overview
- This case concerns the appeal of Emilio Santos V Delgado from the decision of Branch XLIX of the Regional Trial Court of Manila.
- The trial court convicted the appellant of murder and frustrated murder, sentencing him to reclusion perpetua for the murder of Valentino Guevarra and an indeterminate penalty for the frustrated murder of Francisco Lacsa.
- The appellant did not contest his conviction but sought to invoke mitigating circumstances in his favor.
Crimes and Sentences
- The appellant was found guilty of:
- Murder (Criminal Case No. 90-80422): Convicted under Article 248 of the Revised Penal Code, sentenced to reclusion perpetua, and ordered to pay P7,500.00 in actual damages and P50,000.00 in moral damages to the heirs of the victim.
- Frustrated Murder (Criminal Case No. 90-80423): Convicted and sentenced to an indeterminate term of 8 years and 20 days to 12 years, 5 months, and 11 days of reclusion temporal, along with financial compensation to Francisco Lacsa.
Appellant's Claims
- The appellant's appeal focused on two mitigating circumstances:
- Immediate vindication of a grave offense against an ascendant.
- Incomplete defense of a relative.
Factual Background
- The incident occurred on October 22, 1989, when the victim Valentino Guevarra visited his friend Francisco Lacsa, seeking help regarding a dispute with the appellant's father, Emmanuel Santos.
- Upon arriving at Emmanuel's house, Valentino