G.R. No. 192465 ; June 8, 2011
People of the Philippines, Appellee, vs. Angelito Esquibel y Jesus, Appellant.

FACTS

An Information for Murder was filed against appellant Angelito Esquibel y Jesus for stabbing Clark Baloloy y Tacsagon on February 7, 2003, in Manila. The prosecution alleged that while the victim was washing his hands outside his house with his back turned, Esquibel, a neighbor, suddenly stood up from where he was sitting beside eyewitness Maricel Gaboy (the victim’s cousin) and stabbed Baloloy in the abdomen. The victim managed to go inside his house and, before collapsing, identified his assailant as “Butchoy” (Esquibel) to his parents. He was pronounced dead on arrival at the hospital. The medico-legal report confirmed the cause of death as hemorrhagic shock from a stab wound. The victim’s parents identified Esquibel as “Butchoy” and claimed actual damages for funeral expenses.
The appellant pleaded not guilty and invoked self-defense. He testified that he and the victim had been drinking together earlier that evening, and an altercation occurred where the victim threatened him. Later, as he passed by the victim’s house, he heard Gaboy say “Kuya, nandiyan na,” after which the victim allegedly lunged at him with a knife. He claimed he grabbed the knife and used it to stab the victim in self-defense before fleeing.
The Regional Trial Court (RTC) convicted Esquibel of Murder qualified by treachery, sentencing him to reclusion perpetua and ordering him to pay civil indemnity and actual damages. The Court of Appeals (CA) affirmed the conviction but modified the damages, deleting the award for actual damages due to lack of receipts and awarding temperate, moral, and exemplary damages instead. Esquibel appealed to the Supreme Court, adopting his Appellant’s Brief from the CA, which challenged the credibility of the eyewitness and the appreciation of treachery.

ISSUE

Whether the Court of Appeals erred in affirming the trial court’s conviction of the appellant for the crime of Murder, specifically concerning: (1) the credibility of the lone eyewitness; (2) the positive identification of the appellant as the assailant; and (3) the appreciation of the qualifying circumstance of treachery.

RULING

The Supreme Court DENIED the appeal and AFFIRMED the modified decision of the Court of Appeals.
The Court upheld the findings of the lower courts, giving great weight to the trial court’s assessment of witness credibility. The testimony of the lone eyewitness, Maricel Gaboy, was found to be consistent, straightforward, and unwavering. She positively identified the appellant as the person who stabbed the victim while the latter was in a vulnerable position (washing his hands with his back turned). The defense failed to show any ill motive on her part to testify falsely.
The appellant’s claim of self-defense was rejected. By invoking self-defense, the burden of proof shifted to him to prove its elements, which he failed to discharge. His testimony was deemed self-serving and could not prevail over the positive and credible testimony of the prosecution witness.
The Court also ruled that treachery (alevosia) was properly appreciated. The attack was sudden and unexpected, executed in a manner that ensured the accomplishment of the crime without risk to the appellant. The victim was unarmed and in a defenseless position when stabbed from behind, depriving him of any opportunity to defend himself.
The award of damages by the CA was sustained: ₱50,000.00 as civil indemnity, ₱50,000.00 as moral damages, ₱25,000.00 as exemplary damages (due to the presence of treachery), and ₱20,000.00 as temperate damages (in lieu of unsubstantiated actual damages for funeral expenses).