G.R. No. 115470 October 13, 1999
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ANTONIO MANEGDEG alias “MANING,” accused-appellant.

FACTS

The prosecution established that on June 6, 1992, in Pagudpud, Ilocos Norte, accused-appellant Antonio Manegdeg stabbed and killed Federico Abian. The victim’s wife, Lorie Abian, testified that she, her husband, and their son were inside their isolated house when Federico went to the door to urinate. As Federico held the door frame, a hand suddenly stabbed him in the abdomen. Lorie stood up, peered, and saw her husband holding the knife embedded in his stomach. She then looked out the window and saw Manegdeg fleeing down the ladder. Before dying, Federico identified Manegdeg as his assailant. The defense presented a different version, claiming Manegdeg was elsewhere during the incident and that the killing arose from a land dispute, suggesting the victim’s son as the possible killer. The trial court convicted Manegdeg of murder qualified by treachery and aggravated by dwelling, sentencing him to reclusion perpetua and ordering him to pay damages.

ISSUE

The core issue is whether the trial court erred in convicting accused-appellant of murder based on the evidence presented, particularly regarding the credibility of witnesses and the presence of treachery and dwelling as qualifying and aggravating circumstances.

RULING

The Supreme Court affirmed the conviction. The Court upheld the trial court’s assessment of witness credibility, emphasizing that the testimony of Lorie Abian, who witnessed the crime, was clear, consistent, and credible. Her account was corroborated by her son and the dying declaration of the victim. The defense of alibi was properly rejected as it was not physically impossible for Manegdeg to have been at the crime scene. The Court affirmed the finding of treachery (alevosia). The attack was sudden and unexpected, as the victim was stabbed without warning while exiting his house, depriving him of any chance to defend himself. This manner of execution directly and specially ensured the execution of the crime without risk to the assailant. The Court also affirmed the generic aggravating circumstance of dwelling, as the attack occurred in the victim’s own home, a place where he was entitled to safety and peace. However, the Court modified the damages awarded. While it affirmed the P50,000.00 civil indemnity for death, it deleted the P20,000.00 award for moral damages due to the prosecution’s failure to present sufficient proof of the heirs’ mental anguish during trial. The decision was thus affirmed with modification.