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Digest - People vs. Solar y Dumbrique

The Supreme Court affirmed the conviction of Rolando Solar y Dumbrique for murder, reversing the Court of Appeals' downgrade to homicide due to insufficient details on treachery. The Court found the eyewitness testimony credible and established guidelines for prosecutors to properly allege qualifying and aggravating circumstances in Informations. Damages awarded to the victim's heirs were increased to P75,000 each for civil indemnity, moral damages, and exemplary damages, along with P50,000 for temperate damages.

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66 views2 pages

Digest - People vs. Solar y Dumbrique

The Supreme Court affirmed the conviction of Rolando Solar y Dumbrique for murder, reversing the Court of Appeals' downgrade to homicide due to insufficient details on treachery. The Court found the eyewitness testimony credible and established guidelines for prosecutors to properly allege qualifying and aggravating circumstances in Informations. Damages awarded to the victim's heirs were increased to P75,000 each for civil indemnity, moral damages, and exemplary damages, along with P50,000 for temperate damages.

Uploaded by

mclaire.hipolito
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as PDF, TXT or read online on Scribd
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Title

People vs. Solar y Dumbrique

Case Decision Date


G.R. No. 225595 Aug 6, 2019

Accused-appellant found guilty of murder, but conviction downgraded to homicide due


to lack of specific facts on treachery in the information; court rules that accused-
appellant waived his right to question defects in the information and establishes
guidelines for prosecutors to properly allege qualifying and aggravating circumstances.

Case Digest (G.R. No. 225595)


Comprehensive

Facts:
The accused-appellant, Rolando Solar y Dumbrique (Rolando), along with Mark
Kenneth Solar (Mark Kenneth), was charged with the murder of Joseph Capinig y Mato
(Joseph) on March 9, 2008, in Las Piñas City.
The Information alleged that Rolando and Mark Kenneth conspired to attack Joseph
with a baseball bat, causing fatal injuries.
During the arraignment, Rolando pleaded not guilty, while Mark Kenneth remained at
large.
The prosecution presented Ma. Theresa Capinig (Ma. Theresa), Joseph's wife, as an
eyewitness, and Dr. Voltaire Nulud, who conducted the medical examination.
Ma. Theresa testified that she saw Rolando and Mark Kenneth attack Joseph, leading to
his death.
Rolando denied the accusations, claiming self-defense.
The Regional Trial Court (RTC) convicted Rolando of murder, sentencing him to
reclusion perpetua and ordering him to pay damages.
Rolando appealed to the Court of Appeals (CA), which downgraded the conviction to
homicide due to insufficient details on treachery in the Information and modified the
damages awarded.
Rolando then appealed to the Supreme Court.

Issue:
Whether the CA erred in convicting Rolando despite the prosecution's failure to prove
his guilt beyond reasonable doubt.
Whether the CA erred in convicting Rolando despite the prosecution's failure to prove
that conspiracy exists.

Ruling:
The Supreme Court affirmed Rolando's conviction for murder, reversing the CA's
downgrading of the offense to homicide.
The Court modified the damages awarded to the heirs of Joseph, increasing them to
P75,000 each for civil indemnity, moral damages, and exemplary damages, and
awarding P50,000 as temperate damages.

Ratio:
The Supreme Court held that the testimony of Ma. Theresa was credible and sufficient
to establish Rolando's guilt beyond reasonable doubt.
The Court emphasized that appellate courts generally do not overturn the factual
findings of trial courts, especially on witness credibility.
The Court found that Rolando's failure to object to the sufficiency of the Information
constituted a waiver of his right to question it.
The Court noted that the Information, although lacking specific details on treachery,
was sufficient to inform Rolando of the charges against him.
The Court established guidelines for prosecutors to properly allege qualifying and
aggravating circumstances in Informations, emphasizing the need for particularity to
ensure the accused's right to be informed of the charges.
The Court directed that future Informations must state the ultimate facts relative to
qualifying or aggravating circumstances, and prosecutors must attach resolutions
finding probable cause to the Informations.

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