GR 112015; (May, 1995) (Digest)
G.R. No. 112015 May 26, 1995
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RENATO DAEN, JR., a.k.a. “NONOY DAING,” accused-appellant.
FACTS
Accused-appellant Renato Daen, Jr. was charged with murder for the killing of Mario Ponce, Jr. on September 9, 1990, in Quezon City. The altercation stemmed from an earlier complaint by Ponce about a stolen rooster, which he suspected was taken by Daen and his companions. After a barangay mediation that afternoon proved inconclusive, Daen and his group resumed drinking at a nearby party. Later that evening, some members of the group went to Ponce’s residence, leading to a confrontation.
At the scene, prosecution witness Bernardino Lazo testified from a balcony that he saw Daen and five others surround the unarmed victim. Someone held Ponce’s hands, and Daen then stabbed him twice with his left hand. The defense presented a contrary version, claiming it was another cohort, Noning Suyat, who stabbed Ponce after being pushed. The trial court convicted Daen of murder, sentencing him to reclusion perpetua and ordering him to pay damages.
ISSUE
The core issue is whether the prosecution proved beyond reasonable doubt that Renato Daen, Jr. was the perpetrator of the killing and that the crime was attended by treachery, qualifying it as murder.
RULING
The Supreme Court affirmed the conviction. The Court found the testimony of eyewitness Bernardino Lazo credible, positive, and consistent, clearly identifying Daen as the one who delivered the fatal stab wounds. Lazo’s vantage point from the balcony provided him an unobstructed view of the incident. The defense of denial and the alternative version implicating Suyat were deemed weak and uncorroborated, failing to cast doubt on Lazo’s straightforward account.
Regarding the qualifying circumstance, the Court ruled that treachery was present. The attack was sudden and unexpected, executed in a manner that ensured the victim had no opportunity to defend himself. Daen, with his armed companions, surrounded the unarmed Ponce, and his hands were held by another assailant at the time of the stabbing. This concert of action constituted abuse of superior strength, which is absorbed in treachery. The penalty of reclusion perpetua was thus proper. The civil indemnity was increased to P50,000.00, while actual damages were reduced to P3,500.00, the amount substantiated by receipt.