Case Summary (G.R. No. 137296)
Charge and Penalty
Dionisio Vicente was charged with murder under Article 248 of the Revised Penal Code, as amended by RA 7659. The information specified that the crime was committed on May 30, 1998, where Vicente allegedly attacked the victim with a bladed weapon, resulting in death due to stab wounds. The trial court found Vicente guilty beyond reasonable doubt and sentenced him to reclusion perpetua, along with various indemnities to the heirs of the victim.
Factual Background and Testimonies
During the trial, Vicente invoked self-defense, asserting that he was the victim of aggression from Manuel Quinto. Witnesses for the defense included Vicente's family members and a medical officer who testified about Vicente's injuries. Conversely, prosecution witnesses provided a narrative of the events leading to Quinto's death, establishing that Vicente initiated the attack after a quarrel and a previous altercation involving Quinto and Vicente's brothers-in-law.
Evaluation of Self-Defense
The court evaluated the legitimacy of Vicente's claim to self-defense. It distinguished between retaliation and self-defense, emphasizing that for self-defense to apply, the aggressor’s attack must be ongoing. The court found that after the initial altercation, in which Quinto behaved antagonistically, the situation had de-escalated significantly by the time Vicente stabbed Quinto. Consequently, Quinto was no longer an unlawful aggressor, as evidenced by his attempt to reconcile through a handshake moments before the stabbing.
Credibility of Witnesses
The trial court deemed the testimonies of prosecution witnesses credible, while expressing skepticism regarding the defense witnesses, who were related to the defendant. The consistent accounts provided by neutral witnesses were given more weight than the testimonies of Vicente's family members, who had a natural bias toward him.
Presence of Treachery
The court determined that treachery was present in Vicente’s actions, asserting that the attack was sudden and unexpected. The victim had approached Vicente with an olive branch, unarmed and with no indication of aggression. Therefore, the manner of the attack established treachery, thus qualifying the crime as murder rather than homicide.
Indemnities and Damages
While the trial court awarded various damages, the appellate court assessed the evidence supporting those claims, particularly actual damages, and adjusted the amounts accordingly. They confirmed an indemnity of P50,000.00 fo
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Background of the Case
- The case revolves around the appeal of Dionisio Q. Vicente, who was found guilty of murder by the Regional Trial Court, Branch 42, Dagupan City.
- The decision, dated December 15, 1998, sentenced Vicente to reclusion perpetua and ordered him to indemnify the heirs of the victim, Manuel C. Quinto, Jr., with several monetary amounts for damages.
Charge and Incident Details
- Vicente was charged with murder as per the Information dated July 15, 1998, alleging that he attacked and stabbed Quinto on May 30, 1998, at barangay Gueguesangen, Mangaldan, Pangasinan, with intent to kill, employing treachery and evident premeditation.
- The death of Quinto was attributed to "cardiorespiratory arrest secondary to hypovolemic shock due to a stab wound" according to the Certificate of Death issued by Dr. Ophelia Rivera.
Appellant's Plea and Defense
- Upon arraignment, Vicente pleaded not guilty and invoked self-defense, prompting a reverse trial where witnesses were called to testify for both the defense and the prosecution.
- The defense's narrative included that Vicente was at home during a quarrel involving his brothers-in-law when Quinto, feeling insulted, returned with a steel pipe and threatened Vicente.
- Vicente claimed he acted in self-defense when Quinto attempted to stab him with a knife after extending a gesture of reconciliation.
Prosecution's Version of Events
- The prose