G.R. No. 120701 ; June 19, 2001
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. JONATHAN CRISANTO Y OPIN, accused-appellant.

FACTS

On October 30, 1989, in Manila, accused-appellant Jonathan Crisanto y Opin was charged with Murder for stabbing Rodolfo Ampuan y Deresma with a kitchen knife, causing his death. The prosecution’s version, based on eyewitnesses Antonio Daga and Eleuterio Ajero, states that at about 7:40 p.m., the victim was having a drinking session with Daga and Ajero in Ajero’s house. Appellant suddenly entered the room and, without saying anything, stabbed Ampuan in the chest. Daga parried the second thrust, and Ajero shouted. Daga wrested the knife from appellant, who then fled. The victim walked to his house nearby and was later brought to the hospital where he died. Patrolman David Tuazon investigated, and Dr. Marcial Cenido conducted the autopsy, finding the cause of death to be a penetrating stab wound to the chest. The defense presented an alibi. Appellant testified that he was at home sick with fever from 5:30 p.m. and was asleep until policemen arrested him around 11:30 p.m. His testimony was corroborated by Julieta Nebres and Alvirose Luzardo, who claimed to have seen him at home during the time of the incident. The Regional Trial Court convicted appellant of Murder, sentencing him to reclusion perpetua and ordering him to pay indemnity and damages.

ISSUE

1. Whether the guilt of the accused-appellant for the crime charged was proven beyond reasonable doubt.
2. Whether the qualifying circumstances of treachery and evident premeditation attended the commission of the offense.

RULING

The Supreme Court affirmed the trial court’s decision in toto.
1. On the first issue, the Court held that the prosecution proved appellant’s guilt beyond reasonable doubt. The positive identification by eyewitnesses Daga and Ajero, who knew appellant by the nickname “Turko” and gave a detailed account of the stabbing, prevailed over appellant’s denial and alibi. The Court found no merit in appellant’s claim of inconsistencies in the witnesses’ testimonies, ruling them to be minor and not affecting their credibility. The defense of alibi failed because appellant did not demonstrate it was physically impossible for him to be at the crime scene. The trial court’s assessment of witness credibility was accorded great respect.
2. On the second issue, the Court found that treachery was present. The attack was sudden and unexpected, executed in a manner that deprived the victim of any chance to defend himself. However, the Court agreed with the trial court that evident premeditation was not proven, as there was no evidence of planning or preparation. Consequently, appellant was correctly convicted of Murder qualified by treachery. The penalty of reclusion perpetua and the awards of P50,000.00 as civil indemnity and P24,000.00 as actual damages were affirmed.