G.R. No. 130492. January 31, 2001.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. SALVADOR ARROJADO, accused-appellant.

FACTS

Accused-appellant Salvador Arrojado was charged with the murder of his first cousin, Mary Ann Arrojado. The prosecution established that the accused lived with the victim and her ailing father, acting as a caregiver. In the early morning of June 1, 1996, accused-appellant reported to relatives that the victim had committed suicide. Upon arriving at the scene, the relatives found the victim dead in her room with multiple stab wounds, a kitchen knife nearby, and the room in an orderly state. The postmortem examination revealed ten stab wounds, several of which were fatal. The prosecution presented evidence of a strained relationship between the accused and the victim, who often criticized him.
The defense, however, claimed the victim committed suicide. Accused-appellant testified he discovered the body and, out of fear of being implicated, moved the knife and fabricated the suicide story. He asserted the victim was depressed over family conflicts and financial troubles. The trial court rejected this defense, finding accused-appellant guilty of murder qualified by treachery and sentenced him to reclusion perpetua.

ISSUE

The core issue is whether the guilt of accused-appellant for the crime of murder was proven beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction but modified the penalty. The Court found the trial court’s assessment of witness credibility and the evidence conclusive. The defense of suicide was physically and medically implausible. The nature, number, and location of the wounds—ten stab wounds, including several deep, fatal wounds clustered on the chest and abdomen—were inconsistent with self-infliction. Medical authorities cited by the Court established that suicidal stab wounds are typically single or few, situated on accessible body parts like the chest or abdomen, and are not characterized by the ferocity and multiplicity present here. The orderly crime scene, absent signs of struggle, indicated the victim was attacked while defenseless, establishing treachery.
The Court upheld the finding of treachery but noted that the information also alleged evident premeditation without sufficient proof. An allegation not proven is deemed a mere generic aggravating circumstance. Under the law at the time of the crime, the penalty for murder was reclusion temporal maximum to death. With no aggravating or mitigating circumstances, the penalty was imposed in its medium period, which is reclusion perpetua. Thus, the penalty was correctly affirmed. The Court also sustained the awarded civil indemnity and moral damages.