G.R. No. L-19644; October 31, 1964
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. EUTROPIO ROMAWAK, defendant-appellant.

FACTS

In the early morning of September 2, 1958, the body of Ariston Soriano was found in Dulag, Leyte. An information for murder was filed against Eutropio Romawak. Prosecution witnesses testified that on the evening of September 1, they were having supper with the deceased in a house when the accused violently forced open the door and suddenly stabbed Soriano in the back with a bolo. The victim jumped out a window, and the accused also wounded two other persons present before leaving. The wound caused Soriano’s death. The prosecution established that Romawak and Soriano were rivals for the affection of the same woman.
The accused presented a different version. He claimed he was merely passing by when he saw a fight; he witnessed Soriano jump from the window pursued by another man, Crispino Repalda. He alleged that Repalda then attacked him, and in self-defense, he wounded Repalda. He denied inflicting any wound on Soriano. His account was corroborated by a lone witness.

ISSUE

The issues raised on appeal are: (1) whether the trial court erred in finding the accused guilty beyond reasonable doubt despite his defense, and (2) whether the crime committed was murder qualified by treachery or merely homicide.

RULING

The Supreme Court affirmed the conviction for murder. On the first issue, the Court upheld the trial court’s factual findings and credibility assessments. The conclusions of the trial court command great weight, and the appellant failed to present cogent reasons to overturn them. The prosecution witnesses testified in a clear, positive, and convincing manner, identifying Romawak as the assailant. The Court found the defense tale incredible. The appellant’s presence at the scene was not coincidental, as evidence of a motive—romantic rivalry—was established. His mere denial could not overcome the positive identification by multiple eyewitnesses.
On the second issue, the Court ruled that treachery (alevosia) was present, qualifying the killing as murder. The attack was sudden, with the accused forcing the door open and immediately stabbing the victim, who had his back to the door. This manner of attack ensured that the victim was unable to defend himself. The location of the fatal wound at the back corroborated the suddenness of the assault. The Court agreed with the Solicitor General that these circumstances fully justified the finding of treachery. The appellant’s inconsistent stance—denying the killing altogether while arguing it should only be homicide—further weakened his case. The decision of the trial court sentencing the appellant to reclusion perpetua was affirmed in all respects.