G.R. No. 169246 ; January 26, 2007
People of the Philippines, Plaintiff-Appellee, vs. Nicolas Guzman y Bocbosila, Accused-Appellant.

FACTS

On the evening of November 25, 1999, in Quezon City, accused-appellant Nicolas Guzman and two unidentified companions were having a drinking spree. The victim, 17-year-old Michael Angelo Balber, was passing by when the group suddenly surrounded him. Prosecution eyewitnesses Ronald Santiago and Edgardo Bauto, who were both nearby, testified that they clearly saw the attack from a distance of about five arms’ length. They consistently narrated that Guzman’s two companions first took turns stabbing Michael with a knife. Subsequently, Guzman himself took the knife and also stabbed the victim in the stomach, and even kicked Michael when he was already lying on the ground.
The victim’s father, Danilo Balber, arrived at the scene and saw his son lying on the ground with Guzman and two others nearby. When Danilo approached, the three fled to Guzman’s house. Michael was rushed to the hospital but was pronounced dead. The accused interposed the defense of denial and alibi, claiming he was elsewhere at the time of the incident. The Regional Trial Court convicted Guzman of Murder qualified by treachery and sentenced him to reclusion perpetua, a decision affirmed by the Court of Appeals.

ISSUE

Whether the prosecution proved the guilt of accused-appellant Nicolas Guzman for the crime of Murder beyond reasonable doubt.

RULING

Yes, the Supreme Court affirmed the conviction. The Court found the testimonies of the two eyewitnesses, Ronald Santiago and Edgardo Bauto, to be credible, consistent, and categorical. They positively identified Guzman as one of the assailants and gave a coherent account of how he and his companions took turns stabbing the defenseless victim. The attack was sudden and unexpected, leaving Michael with no opportunity to defend himself, which validly qualified the killing to Murder through treachery. The defense of denial and alibi cannot prevail over these positive identifications, especially as Guzman failed to prove it was physically impossible for him to be at the crime scene.
The Court modified the awarded damages, increasing the civil indemnity, moral damages, and exemplary damages to P50,000.00 each, in line with prevailing jurisprudence. The award for actual damages was deleted for lack of sufficient substantiation but replaced with temperate damages of P25,000.00. The penalty of reclusion perpetua was affirmed, with all damages bearing legal interest until fully paid.