Case Summary (G.R. No. 73656)
Charges and Initial Proceedings
Villapando was charged with murder (CCC-VIII-823(79)) and attempted homicide in two separate cases (Criminal Cases Nos. 770 and 771). The murder charge alleged that Villapando fatally stabbed Saturno Manalo, with the additional circumstances of treachery or evident premeditation. The attempted homicide charges involved Villapando attacking Alicia Beron and Ramon Tolentino, resulting in injuries that required medical attention.
Trial Court's Decisions
After trial, the Regional Trial Court found Villapando guilty. In the murder case, he was sentenced to reclusion perpetua, with additional financial penalties to the victim's heirs. For the attempted homicides, he received a sentence of twenty days for one case and a term ranging from six months and one day to two years and one day for the other.
Appeal and Defense
Dissatisfied with the decisions, Villapando appealed, asserting that the trial court neglected his defense of alibi supported by credible witnesses and failed to adequately address inconsistencies in the prosecution's testimony. The defense aimed to establish that Villapando was in San Pablo City during the incident, supported by testimony from an eyewitness who claimed he was not the assailant.
Court's Analysis of Alibi and Credibility of Witnesses
The Supreme Court found the appeal without merit, emphasizing that for alibi to effectively exonerate a defendant, it must be corroborated by clear evidence proving the impossibility of their presence at the crime scene. The proximity of San Pablo City to Batangas City, along with questionable evidence regarding the timing of a watch purchase, weakened Villapando's alibi.
Identification of the Accused
Eyewitness testimonies from Ramon Tolentino and Nelia Panganiban positively identified Villapando as the assailant. Their accounts described a clear sequence of events leading to the stabbing, with both witnesses directly attributing the attacks to him despite the defense's efforts to discredit them.
Evaluation of Treachery and Other Circumstances
The Court clarified that for treachery to be present, the nature of the attack must indicate premeditation and an assurance of execution without risk to the assailant. In this case, given the lack of evidence regarding how the altercation began, the Court concluded that treachery could not be established, reducing the murder charge to simple homicide.
Final Decisions on Sentencing and Damages
The Court agreed with the trial court's findings on attempted homicides but modified charges against Villapando for inadequate intent to k
...continue readingCase Syllabus (G.R. No. 73656)
Case Citation
- G.R. No. 73656
- Date of Decision: October 5, 1989
- Court: First Division, Supreme Court of the Philippines
- Reported in: 258-A Phil. 112
Parties Involved
- Plaintiff-Appellee: The People of the Philippines
- Defendant-Appellant: Rogelio Villapando y Bunsol
Background of the Case
- The accused-appellant, Rogelio Villapando, was charged with:
- Murder in CCC-VIII-823(79)
- Attempted Homicide in Criminal Cases Nos. 770 and 771.
- Date of Incident: January 14, 1979, at approximately 6:10 PM.
- Location: P. Genato St., Batangas City, Philippines.
Charges Outlined
CCC-VIII-823(79):
- Allegation of attack, assault, and stabbing of Saturno Romulo Manalo, resulting in instantaneous death.
- Qualifying circumstances included treachery or evident premeditation.
Criminal Case No. 770:
- Allegation of attempted homicide against Alicia Beron, who sustained physical injuries requiring medical attention.
Criminal Case No. 771:
- Allegation of attempted homicide against Ramon Tolentino, who suffered serious injuries.
Proceedings and Verdicts
- Trial Court Arraignment: Accused entered a plea of not guilty.
- Trial Court Decisions:
- CCC-VIII-823(79): Sentenced to Reclusion Perpetua (life imprisonment) and ordered to pay indemnities.
- Criminal Case No. 770: Sentenced to 20 days imprisonment.
- Criminal Case No. 771: Sentenced to imprisonment of 6 months to 2 years and 1 day.
- The accused was given credit for preventive imprisonment and directed to serve the most severe penalty first.
Summary of Facts
- The incident occurred at the BLTBCo bus terminal where an altercation arose between Romulo Manalo and the accused.
- Witnesses reported that,