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PEOPLE v. JOSEPH ASILAN Y TABORNAL

This case has been cited 4 times or more.

2013-06-26
LEONARDO-DE CASTRO, J.
Flight is indicative of guilt, but its converse is not necessarily true. Culprits behave differently and even erratically in externalizing and manifesting their guilt. Some may escape or flee a circumstance strongly illustrative of guilt while others may remain in the same vicinity so as to create a semblance of regularity, thereby avoiding suspicion from other members of the community.[16] (Citation omitted.) Moreover, our position on the effects of unexplained flight on the guilt or innocence of an accused remains unchanged. In People v. Camat,[17] we reiterated the jurisprudential doctrine that flight is indicative of guilt in this manner:Flight in criminal law is the evading of the course of justice by voluntarily withdrawing oneself in order to avoid arrest or detention or the institution or continuance of criminal proceedings. In one case, this Court had stated that it is well-established that the flight of an accused is competent evidence to indicate his guilt; and flight, when unexplained, is a circumstance from which an inference of guilt may be drawn. Indeed, the wicked flee when no man pursueth, but the innocent are as bold as a lion. (Emphasis supplied, citations omitted.) From the foregoing, we have no other recourse but to sustain appellant's conviction for the complex crime of Murder with Multiple Attempted Murder. As correctly explained by the Court of Appeals, the single act of pitching or rolling the hand grenade on the floor of the gymnasium which resulted in the death of Ramie Balasa (Balasa) and injuries to other victims constituted a complex crime under Article 48 of the Revised Penal Code which states that when a single act constitutes two or more grave or less grave felonies, the penalty for the most serious crime shall be imposed, the same to be applied in its maximum period. The penalty for the most serious crime of Murder under Article 248 of the Revised Penal Code is reclusion perpetua to DEATH. Thus, applying Article 48, the death penalty should be imposed. However, pursuant to Republic Act No. 9346, the proper sentence therefore is reclusion perpetua without eligibility for parole.
2013-06-19
PEREZ, J.
It is elementary in the rule of evidence that inconsistencies in the testimonies of prosecution witnesses with respect to minor details and collateral matters do not affect the substance of their declaration nor the veracity or weight of their testimony.  In fact, these minor inconsistencies enhance the credibility of the witnesses, for they remove any suspicion that their testimonies were contrived or rehearsed. Further, in People vs. Maglente, this Court ruled that inconsistencies in details which are irrelevant to the elements of the crime are not grounds for acquittal. x x x.[68]
2013-01-23
PEREZ, J.
x x x [O]ur scrutiny of the so-called inconsistencies relied upon by Asilan showed that they only referred to minor details, which did not affect the credibility of the prosecution witnesses.[35]  In People v. Albarido,[36] this Court said: It is elementary in the rule of evidence that inconsistencies in the testimonies of prosecution witnesses with respect to minor details and collateral matters do not affect the substance of their declaration nor the veracity or weight of their testimony.  In fact, these minor inconsistencies enhance the credibility of the witnesses, for they remove any suspicion that their testimonies were contrived or rehearsed.  In People vs. Maglente, this Court ruled that inconsistencies in details which are irrelevant to the elements of the crime are not grounds for acquittal. x x x.[37]
2012-09-15
LEONARDO-DE CASTRO, J.
Contrary to his claim of self-defense, appellant's act of stabbing the victim while he was down demonstrates treachery. We previously ruled that treachery is present when the offender commits any of the crimes against persons, employing means, methods, or forms in the execution, which tend directly and specially to insure its execution, without risk to the offender arising from the defense which the offended party might make.[29]