GR 110558; (July, 1995) (Digest)
G.R. No. 110558 July 3, 1995
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. CELEDONIO B. DE LEON and RUBEN A. ALARCON, accused-appellants.
FACTS
On the evening of November 14, 1988, Cesar Cruz was watching television near the Lucena City pier. Appellants Celedonio de Leon and Ruben Alarcon suddenly seized his hands from behind. De Leon then stabbed Cruz in the upper left back. Eyewitness Edmar Ramirez, who was barely half a meter away under fluorescent lighting, positively identified both appellants. The wounded Cruz managed to run but later died from the single stab wound. Another witness, Dinia Saludes, heard Alarcon shout threats against the crew of Cruz’s boat after the incident. The police later apprehended De Leon and Alarcon aboard their vessel.
The defense presented a different account. De Leon claimed self-defense, alleging Cruz attacked him first with a knife, and he merely grabbed it and stabbed back unintentionally. Alarcon denied participation, stating he merely witnessed a struggle from a distance. The trial court convicted both of Murder, finding conspiracy and treachery. On appeal, they argued the prosecution failed to prove their guilt beyond reasonable doubt and that the qualifying circumstance of treachery was absent.
ISSUE
Whether the conviction of appellants for Murder, qualified by treachery, is proper.
RULING
Yes, the Supreme Court affirmed the conviction. The Court found the prosecution evidence, particularly the credible and consistent eyewitness testimony of Edmar Ramirez, sufficient to establish guilt beyond reasonable doubt. Ramirez had a clear view of the incident from close proximity under adequate illumination and knew both appellants prior to the event. His initial affidavit was corroborated by his subsequent affidavit repudiating a coerved retraction. The flight of appellants and Alarcon’s threatening remark after the stabbing further indicated guilt.
The Court upheld the finding of treachery (alevosia). The attack was sudden and unexpected, executed from behind while the victim was restrained by both assailants, depriving him of any opportunity to defend himself. The manner of attack—seizing the victim’s hands and inflicting a solitary fatal wound to the back—consciously and deliberately ensured its execution without risk to the assailants. This method directly and specifically qualified the killing as Murder. The claim of self-defense by De Leon was rejected for being uncorroborated and inconsistent with the physical evidence and credible prosecution narrative.