GR 140545; (May, 2002) (Digest)
G.R. No. 140545 ; May 29, 2002
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. IRENEO GODOY, accused-appellant.
FACTS
Accused-appellant Ireneo Godoy was charged with Murder for the stabbing death of Alexander Carandang on January 29, 1994, in Sariaya, Quezon. The prosecution presented eyewitness Marlon Leonardo, who testified that while fetching Carandang from his duck farm, he saw Godoy, together with others including Aquilino Godoy, holding the victim. Ireneo Godoy then suddenly drew a bladed weapon and stabbed Carandang in the chest. Leonardo shouted but fled when the group turned their attention toward him. The victim’s mother, Fidela Carandang, and another witness, Arcadio Marasigan, corroborated aspects of the incident and the motive, noting a prior altercation. The post-mortem examination confirmed the fatal stab wound.
The defense interposed alibi, with Godoy claiming he was in Batangas and later in Tiaong, Quezon, at the time of the crime, and was only arrested the following morning. His testimony was corroborated by Mariano Joyas. The Regional Trial Court convicted Godoy of Murder, sentencing him to reclusion perpetua and ordering him to pay various damages to the victim’s heirs.
ISSUE
Whether the trial court erred in convicting accused-appellant Ireneo Godoy of Murder based on the prosecution’s evidence.
RULING
The Supreme Court affirmed the conviction. The Court upheld the trial court’s assessment of witness credibility, giving weight to the positive identification by eyewitness Leonardo, which was clear, consistent, and credible. The defense of alibi was correctly rejected as it was not physically impossible for Godoy to have been at the crime scene. The Court found that the qualifying circumstance of treachery was present, as the attack was sudden and unexpected, depriving the victim of any chance to defend himself, thereby qualifying the killing as Murder. However, the Court modified the awarded damages, increasing the amount for loss of earning capacity to P70,666.66 based on the victim’s proven income, and adjusting other damages accordingly, while sustaining the award for attorney’s fees. The penalty of reclusion perpetua was affirmed.