Charge and Information
The three accused were charged with the crime of murder under Article 248 of the Revised Penal Code, as delineated in an Information signed by Provincial Prosecutor Teresita S. Lopez. The Information detailed the act of conspiracy among the accused, who, with treachery and abuse of superior strength, attacked Manuel Tingoy with bolos, leading to his death. The arraignment of the accused took place on November 22, 1999, where Efren and Edwin pleaded not guilty.
Outline of Proceedings
A pre-trial conference occurred on December 7, 1999, followed by a trial where the prosecution presented witnesses, including Eva Castaño, a passerby, and Dr. Nemia Yebron-Sangrano, the Municipal Health Officer, who provided expert testimony regarding the victim's injuries. The defense called upon testimonies from the accused themselves, leading to significant discrepancies in the narratives presented.
Prosecution's Version
The prosecution's account states that on the morning of October 27, 1998, while driving a jeepney, Romeo Ortega stopped for Dioscoro and Eddie Verona. Subsequently, Edgar attempted to stab Ortega, resulting in injuries to a female passenger. Eyewitness Eva Castaño observed the accused carrying different types of bolos, and she testified to the brutal attack on Manuel Tingoy, who was stabbed multiple times, leading to his death.
Defense's Version
The defense argued that the accused were not present during the killing. Edwin testified to being nearby, and Efren claimed he was at his uncle's house watching television during the incident. Dioscoro, who died during the trial, asserted he was unaware of any wrongdoing. The defense sought to portray the incident as a mutual combat between Edgar and Manuel, downplaying the involvement of Efren and Edwin.
Ruling of the Regional Trial Court
The Regional Trial Court, in its February 20, 2012 judgment, found Efren and Edwin guilty of murder, citing the aggravating circumstances of treachery, abuse of superior strength, and conspiracy, concluding that the prosecution’s account was credible and compelling. They were sentenced to reclusion perpetua without eligibility for parole and were ordered to pay damages to the heirs of the victim.
Ruling of the Court of Appeals
On August 1, 2016, the Court of Appeals upheld the Regional Trial Court's decision, modifying the penalty regarding parole eligibility. The appellate court emphasized the deference given to trial court findings regarding witness credibility and the sufficiency of evidence linking Efren and Edwin to the crime.
Issues on Appeal
In their appeal, Efren and Edwin contended that the prosecution's witness, Eva Castaño, lacked credibility, argued against the prosecution's established conspiracy, questioned the appreciation of treachery, and claimed that the circumstance of abuse of superior strength should be absorbed by the treachery finding.
Analysis of Credibility and Evidence
The court found no merit in the defense's claims, asserting that minor inconsistencies in Castaño's testimony did not undermine her overall credibility. The court emphasized tha
...continue readingThe Case
- This case involves an ordinary appeal seeking to reverse the Decision dated August 1, 2016, by the Court of Appeals in CA-G.R. CEB-CR HC No. 01481.
- The appeal concerns the conviction of accused Eddie Verona and accused-appellants Efren and Edwin Verona for the murder of Manuel Tingoy, as established by the Regional Trial Court of Tacloban City in Criminal Case No. 99-01-42.
- The original Judgment was rendered on February 20, 2012, finding the accused guilty beyond reasonable doubt.
The Charge
- The accused were charged with murder under Article 248 of the Revised Penal Code.
- The Information, signed by Provincial Prosecutor Teresita S. Lopez, detailed that on October 27, 1998, in Tanauan, Leyte, the accused conspired to kill Manuel Tingoy using bolos and attacked him while he was aboard a passenger jeepney.
Procedural History
- The accused pleaded not guilty during their arraignment on November 22, 1999, and a pre-trial conference was held on December 7, 1999.
- The trial featured testimonies from both the prosecution and defense witnesses, including medical evidence.
Version of the Prosecution
- The prosecution's case was supported by eyewitness accounts and a medical necropsy report.
- Ms. Eva Castaño, a motorcycle rider, observed the incident where the accused flagged down the jeepney driven by Romeo Ortega.
- The victim, Manuel, was attacked suddenly by Efren and Edwin after the jeepney stopped.
- Multiple stab wounds inflicted by different accused caused Manuel’s death, characterized in the necropsy report as severe hemorrhage due to stab wounds.
Version of the Defense
- The defense pr