THE PEOPLE OF THE PHILIPPINES, vs. PEDRO SALAZAR y JIMENEZ @ "JUNIOR;" DIONISIO AGUILAN y MARARAC @ "DIONE;" LEONARDO AGUILAN y MARARAC @ "LOLLY;" and AGUEDO RAMOS y PALISOC @ "JESSIE"s.
- G.R. Number: G.R. No. 84391
- Promulgated: 1993-04-07
Doctrine
Credibility cannot be impeached merely by asserting that a person should not have acted as he did; people react differently to situations and actions cannot be stereotyped.
A finding of conspiracy may be sustained on the record (court upheld trial court's conclusion that conspiracy existed among the accused).
Conviction may be affirmed while the appellate court adjusts civil indemnity based on its assessment of appropriate damages.
Facts
The People of the Philippines prosecuted Pedro Salazar and three co-accused (named) in Criminal Case No. 3299 before the Regional Trial Court of Pangasinan, Branch 39.
The trial court convicted the accused; the conviction was appealed to the Supreme Court (Second Division).
The Supreme Court majority found conspiracy among the accused.
The Court affirmed the conviction but modified the civil indemnity awarded to the heirs of the victim, increasing it to P50,000.00.
Issues
Whether conspiracy existed among the accused.
Whether the convictions of the accused should be affirmed.
Whether the civil indemnity awarded to the heirs should be modified and, if so, to what amount.
Ruling
Yes — the Court held that conspiracy existed among the accused (finding stated under heading III).
Yes — the Court affirmed the convictions of the accused as proved beyond reasonable doubt.
The Court modified the civil indemnity, increasing it to P50,000.00 payable to the heirs of the victim.
Keywords
G.R. No. 84391, credibility of witnesses, findings of fact of the trial court, alibi, physical impossibility, positive identification, dying declaration, requisites of dying declaration, children as witnesses, burden of proof in self-defense, self-defense, unlawful aggression, actual sudden and unexpected attack, indemnity for death, P50,000 civil indemnity, Article 248 of the Revised Penal Code, Murder, Reclusion Perpetua, moral damages, Art. 219 of the New Civil Code