CASE BRIEFS AND SYNTHESIS OF RELEVANT CASES

I. CASE BRIEFS

A. Rivera v. People, G.R. No. 166326, January 25, 2006

Facts: Ruben Rodil and the Rivera brothers are neighbors. One fine day, a heated verbal
altercation ensued between Rodil and Edgardo Rivera. The following day, Rodil went to a store
near his house in Imus Cavite, tagging along his three-year-old daughter. Suddenly, in an
unexpected manner, the Rivera brothers (Esmeraldo, Ismael and Edgardo) emerged from their
house and ganged up on Rodil.

Ismael and Esmeraldo mauled Rodil with fist blows which caused the latter to fall to the ground.
While in that helpless position, Ruben was hit three times with a hollow block on the parietal area
by Edgardo. When policemen on board a mobile car arrived, the Rivera brothers fled to their
house. Rodil was then brought to the hospital for treatment. According to the medical certificate,
Rodil sustained only a superficial wound in the parietal area.

An Infomation was filed in RTC Cavite, charging the Rivera brothers of attempted murder.
RTC rendered judgment finding all the accused guilty of FRUSTRATED murder. However, the
CA modified the RTC decision, finding all the accused guilty of ATTEMPTED murder. Hence, the
accused filed to the SC the instant petition for review insisting that the prosecution failed to prove
intent to kill on their part and thus they should be held criminally liable only for physical injuries.
In addition, the petitioners also alleged that even if intent was present, prosecution failed to prove
treachery; hence, they should be guilty only of attempted homicide.

Issue: Whether or not prosecution was able to prove intent to kill on the part of the
accused?

Ruling: Yes, the prosecution was able to prove intent to kill on the part of the accused.

An essential element of murder and homicide, whether in their consummated, frustrated or

attempted stage, is intent of the offenders to kill the victim immediately before or simultaneously
with the infliction of injuries. The evidence to prove intent to kill may consist in the means used,
the nature, location and number of wounds sustained by the victim.

In the case at bar, Esmeraldo and Ismael pummeled Rodil with fist blows. Even as Rodil fell
to the ground, unable to defend himself, Edgardo still hit him on the parietal area of the head three
times with a hollow block.

Petition for review is denied for lack of merit.

B. People v. Villalba y Duran, G.R. No. 207629, October 22, 2014

Facts: After attending a farewell party for his students, Maximillian chanced upon accused-
appellants (Arnel Duran and Randy Sarco) and their girlfriends. Maximillian suddenly ordered
accused-appellants to wear their shirts, and then asked accused-appellant Arnel, “How much is
that?” referring to accused-appellant Arnel’s girlfriend. Maximilliana and accused-appellant
continued to stare at each other.

Moments later, Maximillian tried to get hold of accused-appellant Arnel’s left arm but the latter
was able to wave away Maximillian’s hand. Accused-appellant Randy blocked Maximillian’s way
and held Maximillian’s hand/s as accused-appellant Arnel hit Maximillian on the chest and
abdomen. Accused-appellants ran away when Maximillian’s companions came to his aid.

Maximillian claimed that he was stabbed. His wife, Josephine, brought him home assuming
that he was simply drunk and in pain because of the fist fight. However, when they were already
at their house, Josephine felt that Maximilian had no more pulse and his eyes had turned white.
The delay in the discovery of the fatal chest wound and the lack of hospital facilities rendered it
too late to save Maximillian.

Josephine reported the incident to the police. Accused-appellants deny any criminal liability.
Arnel avers that he was acting in self-defense and that he only used a barbeque stick he found
as a weapon to defend himself.

The Trial Court found the prosecution had duly established the essential elements of murder,
and rejected the uncorroborated claim of self-defense of accused-appellant Arnel and defenses
of denial and alibi of accused-appellant Randy. The Court of Appeals rendered its assailed
Decision affirming the conviction of accused-appellants for murder. Hence, this appeal.

Issue: Whether or not accused-appellants are guilty beyond reasonable doubt of the crime
of murder?

Ruling: No, accused-appellants are not guilty of the crime of murder.

Anent the alleged conspiracy between the two accused, it is found that there is no clear
evidence that accused-appellants had a common design to kill Maximillian. Accused-appellant
Randy’s presence at the time and place of Maximillian’s stabbing does not necessarily mean that
the former should bear criminal liability for the latter’s death.

There was no proof that accused-appellant Randy had prior knowledge that accused-
appellant Arnel carried a sharp weapon with him or that accused-appellant Arnel intended to stab
Maximillian. Moreover, that accused-appellant Arnel used a barbecue stick he found in the area
as a weapon shows that he acted instantaneously and spontaneously in stabbing Maximillian,
thus, further negating the possibility that he conspired with accused-appellant Randy to commit
the stabbing.

The prosecution likewise failed to prove beyond reasonable doubt any of the alleged
circumstances which would qualify the killing of Maximillian to murder. That accused-appellant
Randy was present or that Maximillian was unarmed and drunk at the time of the stabbing are not
sufficient to constitute treachery. Neither do said circumstances constitute abuse of superior
strength.

Hence, accused-appellant Arnel is convicted only of homicide and accused-appellant Randy

is absolved of any criminal liability.
People v. Oandasan, Jr., G.R. No. 194605, June 14, 2016

Facts: