G.R. No. 121898 January 29, 1998
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RENE H. ARANJUEZ, accused-appellant.

FACTS

On December 19, 1993, at around 1:00 a.m., Godofredo Ferrer, his wife Filomena, and their children were awake in their house in Bacolod City. Their house and store lights were on, illuminating their front yard. They heard a commotion outside and saw a group including Ananias Lugmao, Armando Aranjuez, and Dodoy Roxas. Ananias Lugmao was shouting and challenging a neighbor, Siegfredo Lomugdang, to a fight, stemming from a quarrel at a nearby dance hall. Godofredo Ferrer intervened. While Filomena Ferrer was inquiring about the incident, accused-appellant Rene Aranjuez suddenly appeared from behind gumamela plants in the yard and, without any reason, stabbed Godofredo Ferrer several times with a bladed weapon. Filomena Ferrer and her son Rex Ferrer, who were standing about two to three meters away, clearly saw the accused-appellant. The victim was rushed to the hospital but was declared dead on arrival. The accused-appellant fled with his cohorts. He was charged with murder qualified by treachery and evident premeditation. The Regional Trial Court convicted him of murder and sentenced him to reclusion perpetua, ordering him to indemnify the victim’s heirs. Accused-appellant denied the accusation, claiming he was asleep at his workplace in another part of Bacolod at the time and only learned of the incident later, prompting him to flee to Iloilo due to fear of retaliation. He attempted to implicate his cousin, Armando Aranjuez.

ISSUE

1. Whether the trial court erred in giving full credence to the testimonies of the prosecution witnesses and in disregarding the defense’s theory.
2. Whether the trial court erred in finding the existence of treachery qualifying the crime to murder.

RULING

The Supreme Court affirmed the decision of the trial court.
1. The trial court did not err in crediting the prosecution witnesses. Their positive identification of the accused-appellant was reliable due to the well-lit area, their proximity (2-3 meters) to the crime scene, their prior acquaintance with the accused-appellant, and the absence of ill motive to falsely testify. Their testimonies were given with candor and consistency. The relationship of the witnesses (wife and son) to the victim did not impair their credibility but rather strengthened it, as they would be deterred from implicating an innocent person. The defense of alibi was properly rejected as it was uncorroborated and failed to prove the physical impossibility for the accused-appellant to be at the crime scene, given that both locations were within the same barangay. His sudden flight to Iloilo and subsequent hiding were indicative of guilt.
2. The trial court correctly found treachery. The attack was sudden and unexpected, with the accused-appellant emerging from concealment behind plants, giving the victim no opportunity to defend himself. The fact that the attack was frontal did not negate treachery, as the essence is the execution of the attack in a manner that ensures the assailant’s safety from any defense the victim might make. The qualifying circumstance of evident premeditation was not proven. The penalty of reclusion perpetua and the award of P50,000.00 as civil indemnity were affirmed.