Case Summary (G.R. No. 251636)
Factual Background
On the night of the incident, Sullano and Orillo were attending a wake where a confrontation between them and Villaruel ensued after verbal exchanges escalated into physical violence. Sullano reportedly delivered the first blows, while Orillo allegedly wielded a knife and delivered a fatal stab wound to Villaruel. Witness testimony established that Sullano handed Orillo the knife shortly before the stabbing, reflecting a collaborative effort to inflict harm.
Trial Court Proceedings
During the trial, Sullano pleaded not guilty. The prosecution presented several witnesses, including Morito Dingcong, who testified to seeing both accused attacking Villaruel. Key pieces of evidence included an autopsy report indicating that Villaruel died from a stab wound inflicted by Orillo. The trial court found Sullano guilty of murder, reasoning that the actions of the two accused constituted conspiracy, leading to the conclusion that both were equally liable for the crime.
Conspiracy and Criminal Liability
Sullano's defense posited that there was insufficient evidence of conspiracy. He argued that his actions were separate from those of Orillo since he did not deliver the fatal stab. However, the court asserted that criminal conspiracy does not necessitate a formal agreement but can be inferred from the coordinated conduct of the individuals involved. The presence of multiple wounds on the victim indicated that both accused participated in the assault. As such, the court maintained the principle that where there is conspiracy, the acts of one may be attributed to all.
Credibility of Witnesses
The appeal cited concerns regarding the credibility of the witnesses, particularly claiming that a key witness, Domingo Doronila, had fabricated testimony against Sullano. The appellate court, however, found no compelling reason to overturn the trial court's determinations on credibility, emphasizing that the trial court is in the best position to evaluate the behavior and reliability of witnesses during testimony.
Flight as Evidence of Guilt
Sullano's flight after the incident was highlighted as an indicator of guilt. He left Iloilo shortly after the stabbing and did not return until several weeks later. The court referenced established jurispru
...continue readingCase Syllabus (G.R. No. 251636)
Case Overview
- Case Number: G.R. No. 125896
- Decision Date: May 11, 2000
- Court: Second Division of the Supreme Court of the Philippines
- Parties Involved: The People of the Philippines (Plaintiff-Appellee) vs. Angelo Orillo (At Large) and Steve Sullano (Accused-Appellant)
- Lower Court: Regional Trial Court, Branch 35, Iloilo City
- Initial Verdict: Accused-Appellant found guilty of murder, sentenced to reclusion perpetua, and ordered to pay indemnities to the heirs of the victim.
Facts of the Case
- Incident Date: March 19, 1994
- Location: City of Iloilo, Philippines
- Context: The incident occurred during a wake for a local resident, Cipriano Veloso, where attendees engaged in games.
- Victim: Felix Villaruel, who appeared intoxicated at the time of the incident.
- Accused: Steve Sullano and Angelo Orillo, both present at the wake.
- Initial Conflict: Villaruel threatened his nephew, "Burnog," and confronted the accused, leading to a physical altercation where Villaruel was assaulted by Sullano and Orillo.
Sequence of Events
- Villaruel confronted Sullano and engaged in a physical altercation, during which Sullano delivered punches and kicks.
- Orillo assisted in restraining Villaruel, allowing Sullano to continue the assault.
- After the altercation, Orillo returned with a knife and fatally stabbed Villaruel.
- Villaruel's father, Jose, attempted to intervene but was also threatened by Orillo.
- Villaruel was transported to the hospital but succumbed to his