G.R. No. 98401 January 27, 1994
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. EDDIE INOCENCIO y ROZAGA, accused-appellant.

FACTS

On Christmas Eve of 1989, between 11:00 PM and 12:00 midnight, Lolita Cariaga asked her son Eduardo to buy a broom. On his way, Eduardo saw his brother Abelardo waiting for his wife Lora. Eduardo then saw Jojo dela Cruz hit Abelardo’s head with a bottle, leading to a brief fistfight. Jojo fled into the Myer’s Building. After Lolita inquired about the incident, Jojo, Eddie Inocencio, Pepito dela Cruz, Jose dela Cruz, and a cousin of Pepito emerged from the building armed with bladed weapons and a lead pipe. Eduardo and Abelardo, outnumbered and unarmed, ran. The group caught Abelardo at a street corner, ganged up on him, and repeatedly stabbed him. Eduardo was hit with a lead pipe when he tried to help. Lolita tried to pacify the assailants but failed. Both Lolita and Eduardo saw Eddie Inocencio deliver a stabbing blow to the left side of Abelardo’s chest. Abelardo was brought to the hospital and declared dead on arrival from three stab wounds, one of which lacerated his heart. Patrolman Nelson Sarsonas investigated, and Lolita and Eduardo positively identified Inocencio, who was being treated for a stab wound at a hospital, as one of the assailants. He was arrested. An Information for Murder was filed against Eddie Inocencio alone, as the others remained at large. He pleaded not guilty. The trial court found him guilty of Murder and sentenced him to Reclusion Perpetua and ordered him to pay moral damages. Inocencio appealed.

ISSUE

Whether the trial court erred in finding accused-appellant Eddie Inocencio guilty beyond reasonable doubt of the crime of Murder.

RULING

The Supreme Court AFFIRMED the trial court’s decision, with the modification of increasing the civil indemnity to fifty thousand pesos (P50,000.00). The Court held that the minor inconsistencies in the testimonies of prosecution witnesses Lolita and Eduardo Cariaga were inconsequential and did not destroy their credibility, as they were consistent on the essential fact that they saw accused-appellant deliver the fatal stabbing blow. The Court sustained the trial court’s finding that Inocencio’s own stab wound could have been accidentally inflicted by his co-assailants during the frenzied attack. The Court gave scant consideration to Inocencio’s claim that he did not inform the police of the real assailants due to fear, finding it contrary to human experience for an innocent person to remain silent and face incarceration. Finally, the Court ruled that Inocencio’s non-flight was not voluntary as he was wounded and hospitalized, where he was apprehended, and that non-flight is not invariably an indication of innocence. The prosecution evidence proved his guilt beyond reasonable doubt.