Case Summary (G.R. No. 144442)
Criminal Complaints
The first criminal complaint (Criminal Case No. U-9275) charged Jesus Salvatierra, Sr., Jesus Salvatierra, Jr., and Alfredo Bedar with inflicting injuries on William Campos, while the second complaint (Criminal Case No. U-9276) involved Jesus Salvatierra, Sr. stabbing Dominador Campos. The injuries inflicted on William Campos included stab wounds to critical areas that could potentially lead to death, thus constituting the crime of frustrated homicide.
Summary of Prosecution Evidence
Testimony from William Campos indicated that on the night of the incident, he was walking home after work when Jesus Salvatierra, Sr. confronted him aggressively. After an exchange of words, the petitioners attacked William, restraining him while Salvatierra, Sr. stabbed him with a dagger. Dominador Campos responded to William's cries for help but was also subsequently stabbed by Salvatierra, Sr.
Defense's Position
The defense attempted to establish an alibi for Salvatierra, Sr. and claimed he acted in self-defense, citing that he and his son had been attacked by William and Dominador Campos. They asserted that William had been caught stealing ducks, which led to a physical altercation where Salvatierra, Sr. defended himself with a spading fork before using a knife.
Trial Court Decision
The Regional Trial Court found the Salvatierras guilty of frustrated homicide and sentenced them to imprisonment, specifying penalties under the Revised Penal Code. The trial court noted the gravity of the accusations and the injuries sustained by the victims, affirming that the actions of Salvatierra, Sr. and Salvatierra, Jr. amounted to a conspiracy to commit the crimes.
Court of Appeals Ruling
The Court of Appeals affirmed the trial court's decision with modifications to the sentencing. Jesus Salvatierra, Sr. was sentenced to an indeterminate penalty that included a reduced minimum sentence, while Salvatierra, Jr. was sentenced to a lesser term considering his young age. The appellate court also removed the civil liability awards to the complainants.
Petitioners' Allegations of Error
The petitioners challenged the Court of Appeals rulings on the grounds that the testimonies of the prosecution witnesses lacked credibility and that the existence of a conspiracy was improperly determined. They contested the affirming of their conviction and sought relief from the appellate court's modifications.
Supreme Court's Affirmation of Lower Court Rulings
The Supreme Court, upon reviewing the case, affirmed the decision of the Court of Appeals. It highlighted the trial court's role in assessing witness credibility, which was deemed consistent and supported b
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Case Overview
- This case involves a petition for review on certiorari by Jesus Salvatierra, Sr. and Jesus Salvatierra, Jr. against the decision of the Court of Appeals, which modified their conviction for two counts of frustrated homicide.
- The initial trial was held in the Regional Trial Court of Urdaneta, Pangasinan, Branch 48, resulting in the conviction of the petitioners in Criminal Case Nos. U-9275 and U-9276.
Background of the Case
- The case originated from two criminal complaints for frustrated homicide:
- Criminal Case No. U-9275 involved the stabbing of William Campos.
- Criminal Case No. U-9276 involved the stabbing of Dominador Campos.
- Both incidents occurred on February 18, 1997, in Barangay Cauringan, Sison, Pangasinan.
Facts of the Case
- Incident Details:
- William Campos was attacked by the petitioners, armed with a dagger, after an altercation initiated by Salvatierra, Sr. accusing him of harming his dog.
- While William was being restrained by Salvatierra, Jr. and Alfredo Bedar, he was stabbed twice by Salvatierra, Sr.
- Dominador Campos, William's brother, responded to his cries for help and was also stabbed by Salvatierra, Sr. during the ensuing struggle.
- Medical Evidence:
- Both victims received timely medical assistance, which prevented their deaths, thus leading to the charge of frustrated homicide.
Trial Court Proceedings
- The trial court convicted the Salvatierras but acquitted Alfr