GR 192818; (November, 2010) (Digest)
G.R. No. 192818 ; November 17, 2010
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. PRINCE FRANCISCO y ZAFE, Accused-Appellant.
FACTS
Accused-appellant Prince Francisco was charged with Murder for stabbing Ramil Tablate to death on October 24, 2001, in Virac, Catanduanes. During pre-trial, he withdrew his original plea of not guilty and pleaded guilty to the charge. The Regional Trial Court (RTC), after conducting a searching inquiry to ensure the plea was voluntary and intelligent, accepted the plea but nonetheless set the case for hearing to receive evidence on his culpability. The prosecution presented witnesses who testified that the appellant suddenly appeared from behind the victim, who was seated on a parked motorcycle, and relentlessly stabbed him multiple times despite pleas from the victim and his brother, Christopher. The defense admitted the killing but argued it constituted only Homicide, not Murder, contending the attack was not treacherous.
ISSUE
Whether the qualifying circumstance of treachery was duly proven to convict the appellant of Murder despite his plea of guilty.
RULING
Yes, the Supreme Court affirmed the conviction for Murder. A plea of guilty to a capital offense does not automatically result in conviction; the prosecution must still prove the accused’s guilt and the precise degree of culpability beyond reasonable doubt. Here, the prosecution evidence sufficiently established treachery (alevosia). The attack was sudden and from behind, giving the unarmed victim, who was seated and conversing, no opportunity to defend himself or repel the assault. The means of execution were deliberately and consciously adopted by the appellant to ensure the killing without risk to himself. The number, nature, and location of the victim’s wounds—16 wounds, 13 of which were stab wounds—further demonstrated a determined effort to kill. The Court found no merit in the defense’s claim of a frontal attack, as it was contradicted by consistent eyewitness testimony. Thus, the killing was qualified by treachery, elevating the crime from Homicide to Murder. The penalty of reclusion perpetua and the awarded damages were affirmed.