In a ruling highlighting the judiciary’s commitment to protecting vulnerable members of society, the Supreme Court affirmed the conviction of Cresenciano Enojo for the murder of three children and the frustrated murder of their mother. The Court emphasized the importance of factual averments in indictments, especially when dealing with aggravating circumstances like treachery. This decision underscores the principle that crimes against children are viewed with utmost gravity and that the rights of the accused must be carefully balanced with the need to ensure justice for victims.

From Dog’s Wound to Deadly Blows: When Does a Heated Confrontation Escalate to Murder?

The case began with a seemingly minor incident: a child, Delfred Cuevas, struck Cresenciano Enojo’s dog with a slingshot. This led to a heated exchange where Enojo threatened the child and his family. Later, when Delfred’s mother, Carmen Cuevas, confronted Enojo about the threats, he attacked her with a bolo. The situation escalated tragically as Enojo then turned on Carmen’s children, resulting in the deaths of Delfred, Alfred, and Chrocila Cuevas, and the serious wounding of Carmen herself. The central legal question became whether Enojo’s actions constituted murder and frustrated murder, and whether the aggravating circumstances of treachery and abuse of superior strength were properly considered.

The Regional Trial Court (RTC) found Enojo guilty of three counts of murder for the deaths of the children and one count of frustrated murder for the attack on Carmen. The RTC emphasized the treachery involved in the killings, given the children’s vulnerability due to their young age. The Court of Appeals (CA) affirmed this decision, modifying only the award of damages to align with current jurisprudence. Dissatisfied with the ruling, Enojo appealed to the Supreme Court, arguing that treachery and abuse of superior strength were not proven beyond a reasonable doubt. He also questioned the credibility of the prosecution’s witnesses, citing inconsistencies in their testimonies.

However, the Supreme Court gave significant weight to the trial court’s assessment of the witnesses’ credibility. The Court stated that trial courts are in the best position to evaluate witness credibility because they can directly observe the witnesses’ demeanor and manner of testifying. Credibility is a cornerstone of evidence and, absent compelling reasons to overturn the trial court’s findings, appellate courts generally defer to those assessments. The Court agreed with the lower courts that the killing of the children was indeed characterized by treachery. The Supreme Court quoted:

The killing of a child is characterized by treachery even if the manner of the assault is not shown in the Information, as the weakness of the victim due to his tender age results in the absence of any danger to the accused.

This principle acknowledges the inherent vulnerability of children and recognizes that any attack on them is inherently treacherous because they cannot adequately defend themselves. In the case of Carmen’s frustrated murder charge, however, the Supreme Court made a critical observation about the importance of specific factual averments in the Information. The Court noted that the Information lacked specific details about how treachery was employed in the attack. The Court emphasized that general allegations of aggravating circumstances are insufficient; the Information must include factual details to ensure the accused is fully informed of the charges against them. This serves as a reminder for prosecutors to be precise in their indictments.

Factual averments constituting not only the offense charged, but also the circumstances that may increase the accused’s liability, must be made in the Information in order to ensure that the accused is fully afforded his right to be apprised of the nature and cause of the accusation against him.

Despite this deficiency, the Court found that abuse of superior strength was evident in the attack on Carmen. The Court stated that an attack by a man wielding a deadly weapon against an unarmed and defenseless woman constitutes abuse of superior strength. In this case, Enojo used a bolo against Carmen, who had no means to defend herself. This circumstance, the Court held, qualified the crime as frustrated murder, even in the absence of treachery. The presence of abuse of superior strength highlighted the power imbalance and the accused’s exploitation of that advantage.

The Court emphasized that the conviction for frustrated murder was valid because the elements of the crime were met. Frustrated murder requires intent to kill, performance of all acts of execution, and failure to consummate the killing due to causes independent of the accused’s will. Dr. Hipe’s testimony confirmed that Carmen’s injuries were potentially fatal and that her survival was due to timely medical intervention. This established the elements necessary for a finding of frustrated murder. This ruling serves as a reminder of the importance of medical evidence in establishing the severity of injuries and the intent behind an attack.

In summary, the Supreme Court affirmed the convictions, underscoring the gravity of crimes against vulnerable victims and the necessity of precise indictments. The Court maintained that the killing of the children was characterized by treachery due to their young age and vulnerability. While treachery was not sufficiently proven in the attack on Carmen, the Court found that abuse of superior strength was present, qualifying the crime as frustrated murder. This decision also serves as a reminder to prosecutors about the importance of including specific factual averments in indictments, especially when dealing with aggravating or qualifying circumstances.

FAQs

What was the key issue in this case?	The key issue was whether the accused was guilty beyond reasonable doubt of murder for killing three children and frustrated murder for attacking their mother, and whether treachery and abuse of superior strength were properly considered.
Why was the killing of the children considered murder?	The killing of the children was considered murder because it was qualified by treachery, given their young age and vulnerability, which made them unable to defend themselves against the accused.
What is the significance of ‘treachery’ in this case?	Treachery is a qualifying circumstance that elevates homicide to murder. It means the offender employed means, methods, or forms in the execution of the crime that tended directly and specially to ensure its execution, without risk to himself arising from the defense which the offended party might make.
Why did the Supreme Court question the frustrated murder charge initially?	The Supreme Court questioned the frustrated murder charge because the Information lacked specific factual details about how treachery was employed in the attack on Carmen, which is required for it to be considered a qualifying circumstance.
What is the importance of factual averments in an Information?	Factual averments are crucial because they ensure that the accused is fully informed of the nature and cause of the accusation against them, especially when aggravating or qualifying circumstances are involved.
How did ‘abuse of superior strength’ factor into the frustrated murder charge?	Although treachery was not sufficiently proven, the Court found that abuse of superior strength was evident because the accused, a man with a bolo, attacked Carmen, an unarmed and defenseless woman.
What elements are required for a crime to be considered ‘frustrated murder’?	Frustrated murder requires intent to kill, performance of all acts of execution that would produce the crime, and failure to consummate the killing due to causes independent of the accused’s will.
What was the role of Dr. Hipe’s testimony in the case?	Dr. Hipe’s testimony was crucial as it confirmed that Carmen’s injuries were potentially fatal and that her survival was due to timely medical intervention, thus establishing the elements necessary for frustrated murder.
What is the practical implication of this ruling for prosecutors?	This ruling serves as a reminder to prosecutors about the importance of including specific factual averments in indictments, especially when dealing with aggravating or qualifying circumstances like treachery.

The Supreme Court’s decision serves as a reminder of the judiciary’s unwavering commitment to protecting the most vulnerable members of society. The ruling also highlights the importance of meticulousness in legal proceedings, particularly in the drafting of indictments. By emphasizing the necessity of detailed factual averments, the Court ensures that the accused are fully aware of the charges against them and that justice is served with the utmost precision. This case stands as a testament to the principle that crimes against children are viewed with utmost gravity and that the rights of both the accused and the victims must be carefully balanced to achieve a just outcome.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: PEOPLE OF THE PHILIPPINES, VS. CRESENCIANO ENOJO, G.R. No. 240231, November 27, 2019