G.R. No. 116294 August 21, 1997
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ANTONIO CHAVEZ y ESTAMANTE alias “TONY”, accused-appellant.

FACTS

The prosecution’s case, primarily through eyewitness Agripina Ablejina, the common-law wife of the victim Bernabe Jaos, established that on the evening of October 18, 1992, Jaos was at the house-store of his brother-in-law, Efraim Navarez, in Siaton, Negros Oriental. Agripina, observing from her nearby home, saw the appellant, Antonio Chavez, arrive and without any provocation, stab Jaos in the abdomen while the victim was squatting near the door. The attack caused Jaos’s intestines to protrude, and he fell to the ground after being pushed by Chavez, who then fled. Agripina retrieved the knife and reported the incident. The medico-legal report confirmed a fatal perforating stab wound. The defense presented a starkly different version, claiming that Navarez was the actual assailant. Appellant testified that he was merely present when Jaos threatened Navarez, who then stabbed Jaos and also wounded appellant in the arm during the ensuing commotion.

ISSUE

The core issue is whether the prosecution proved the guilt of the appellant for the crime of murder beyond reasonable doubt, particularly in light of the conflicting testimonies between the prosecution eyewitness and the defense’s claim of innocence and alternative perpetrator.

RULING

The Supreme Court affirmed the conviction. The Court found the testimony of Agripina Ablejina to be credible, natural, and consistent. As an eyewitness who was in a position to clearly observe the incident, her account was accorded full weight. The Court emphasized that the assessment of witness credibility is best undertaken by the trial court, and its findings are generally binding unless substantial facts were overlooked. The defense of denial and frame-up by the appellant was deemed weak and unsupported by convincing evidence. The Court noted the inherent improbability of the defense narrative, which sought to implicate Navarez, and found no ill motive for Agripina to falsely testify against the appellant. Regarding the qualifying circumstance of treachery, the Court agreed with the trial court that the sudden and unexpected stabbing of the unarmed victim, who was squatting and unable to defend himself, squarely constituted alevosia. The attack was deliberate and employed in a manner that ensured the execution of the crime without risk to the appellant. The penalty of reclusion perpetua was thus correctly imposed. The decision of the Regional Trial Court was affirmed in toto.