G.R. No. 188603 ; January 16, 2013
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. RAMIL RARUGAL alias “AMAY BISAYA,” Accused-Appellant.

FACTS

On the night of October 19, 1998, Arnel Florendo was cycling along Sampaguita Street in Quezon City when accused-appellant Ramil Rarugal stabbed him with a long double-bladed weapon and fled. The incident was witnessed by Roberto Sit-Jar, who positively identified Rarugal in court. The wounded Florendo managed to return home and, in the presence of his siblings, identified Rarugal as his assailant before he was taken to the hospital. Florendo died on October 26, 1998, from a stab wound to the chest. The prosecution presented evidence of actual damages for hospitalization and funeral expenses.
In his defense, Rarugal denied the accusation and interposed alibi, claiming he was working as a farm administrator in Pangasinan on the date of the incident and had not visited Manila during that period. However, on cross-examination, he admitted he was arrested in front of his house in Novaliches, Quezon City.

ISSUE

The core issues were: (1) whether the prosecution proved Rarugal’s guilt beyond reasonable doubt, and (2) whether the qualifying circumstance of treachery was correctly appreciated to elevate the crime to murder.

RULING

The Supreme Court affirmed the conviction for murder. The Court upheld the credibility of eyewitness Roberto Sit-Jar, whose positive identification of Rarugal was clear and categorical. The defense failed to show any ill motive on Sit-Jar’s part to falsely testify. Against this positive identification, Rarugal’s defense of denial and alibi could not prevail. Alibi is inherently weak and becomes even less credible when the accused fails to prove it was physically impossible for him to be at the crime scene. His admission of arrest in Quezon City further undermined his claim of being exclusively in Pangasinan.
Regarding the qualifying circumstance, the Court agreed that treachery was present. The attack was sudden and unexpected, employing a bladed weapon against an unarmed victim who was merely riding a bicycle, depriving him of any chance to defend himself. This manner of execution ensured the commission of the crime without risk to the assailant. The Court modified the awarded damages, upholding the actual damages supported by receipts and awarding civil indemnity, moral damages, and exemplary damages in line with prevailing jurisprudence. The penalty of reclusion perpetua was affirmed.