PEOPLE OF THE PHILIPPINES vs.
BENJAMIN CASAS y VINTULAN
G.R. No. 212565 February 25, 2015
PERLAS-BERNABE, J.:
FACTS:
Two (2) criminal Informations were filed before the RTC charging Casas of
the Murder of Joel Tabiley Gulla (Joel)and the Frustrated Murder of Eligio
Ruiz y Ricardo (Eligio), the pertinent portions of which respectively read:
Crim. Case No. 136842
That, on or about the 24th day of December, 2007, in the City of San Juan,
a place within the jurisdiction of this Honorable Court, the above-named
accused, in conspiracy with another person, whose true identity and
present whereabouts are unknown, with the use of a bladed weapon, a
deadly weapon, with intent to kill and by means of the qualifying
circumstance treachery (sic), evident premeditation and abuse of superior
strength, did, then and there willfully, unlawfully and feloniously attack,
assault and stab one Joel Tabiley Gulla, thereby inflicting upon the latter
several stab wounds on the different parts of his body, which directly
caused his death.
CONTRARY TO LAW
Crim. Case No. 136843
That, on or about the 24th day of December, 2007, in the City of San Juan,
a place within the jurisdiction of this Honorable Court, the above-named
accused, in conspiracy with another person, whose true identity and
present whereabouts are unknown, with intent to kill and by means of the
qualifying circumstance treachery, evident premeditation and abuse of
superior strength, which qualifies the crime to frustrated murder, with the
use of a bladed weapon, a deadly weapon, did, then and there willfully,
unlawfully and feloniously attack, assault and stab one Elegio Ruiz y
Ricardo, thereby inflicting upon the latter several stab wounds on the
different parts of his body, which ordinarily would have caused his death,
thus, performing all the acts of execution which would produce the crime
of murder as a consequence but which nevertheless, did not produce it by
reason of causes independent of the will of the accused, that is, due to the
timely medical assistance rendered unto said Elegio Ruiz y Ricardo, which
prevented his death.
CONTRARY TO LAW.
During arraignment, Casas entered a plea of not guilty. After which, joint
trial on the merits ensued.
(People vs. Casas G.R. No. 212565 February 25, 2015)
ISSUE:
Whether or not Benjamin Casas y Vintulan shall be convicted for 2 criminal
indictments.
RULING:
THE RTC RULING
It declared that the evidence on record did not support Casas's
theory of self-defense, observing that the victims showed no unlawful
aggression towards Casas. On the other hand, the prosecution's witnesses
invariably testified that it was Casas who wielded a knife, brought it to bear
on Eligio, then on Joel as he lay prostrate, and again on Eligio as he was
fleeing, establishing that Casas was the aggressor. Further, it was pointed
out that Casas suffered only nine (9) injuries, consisting of three (3)
abrasions, one (1) contusion, and five (5) incised wounds, which did not,
collectively or individually, threaten his life at any time. Conversely, Joel
was killed because of the stab wounds that Casas inflicted, while Eligio was
stabbed multiple times. As such, the second requirement under Article 11
(1) of the RPC, i.e., the reasonable necessity of the means employed to
repel the unlawful aggression, was non-existent.
The CA Ruling
In a Decision dated November 20, 2013, the CA affirmed the RTC's
conviction of Casas but modified the amounts awarded to P75,000.00 in
civil indemnity, P12,500.00 in actual damages, P37,200.00 in loss of
earning capacity, P30,000.00 in moral damages, and P30,000.00 in
exemplary damages for the Murder of Joel. As for the Attempted Homicide
of Eligio, it awarded P25,000.00 in temperate damages, and ?10,000.00 in
moral damages, in order to conform with recent jurisprudence.
The Court’s Ruling
The appeal is partly meritorious.
The Court first rules on the existence of criminal liability.
