G.R. No. 122477 ; June 30, 2000
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. EDISON ARELLANO, accused-appellant.

FACTS

The accused-appellant, Edison Arellano, was charged with Murder for the stabbing death of Andres Ventura. The prosecution presented eyewitnesses Roberto Morales and Antonio Cordova, who testified that on the evening of July 25, 1993, they were drinking at a store with the victim and others, including co-accused Romeo Tindenilla. An argument arose between Ventura and Tindenilla, escalating into a fistfight. As Tindenilla fell from the victim’s punches, Arellano suddenly approached from behind and stabbed Ventura on the right side of his body with a double-bladed instrument. The victim was brought to the hospital where he died. The trial court convicted Arellano of Murder qualified by treachery and sentenced him to reclusion perpetua.
The defense presented alibi and denial. Arellano claimed he was elsewhere paying respects at a wake at the time of the incident. Co-accused Tindenilla, who was acquitted by the trial court due to lack of conspiracy, testified that he was attacked by the victim and lost consciousness, and was unaware of the stabbing. The defense sought to discredit the prosecution witnesses by alleging inconsistencies in their testimonies.

ISSUE

The core issue is whether the prosecution proved the guilt of the accused-appellant beyond reasonable doubt for the crime of Murder, particularly the attendance of the qualifying circumstance of treachery.

RULING

The Supreme Court modified the trial court’s decision, convicting the accused-appellant of Homicide instead of Murder. The Court affirmed the factual findings of the trial court, giving weight to the positive and categorical testimonies of the two eyewitnesses who consistently identified Arellano as the assailant. Their testimonies were found credible and sufficient to overcome the defenses of alibi and denial, which were weak and uncorroborated.
However, the Court ruled that treachery was not sufficiently established. The qualifying circumstance of treachery requires that the means of execution be deliberately adopted to ensure the victim’s defenselessness. The evidence showed that the stabbing occurred during a sudden tumult arising from a fistfight between the victim and Tindenilla. The attack was not shown to have been consciously and deliberately planned to employ a particular method ensuring the execution of the crime without risk to the assailant. The spontaneity of the act, emerging from a heated altercation, negated the deliberate and calculated manner required for treachery. Consequently, without any qualifying circumstance, the crime committed is Homicide under Article 249 of the Revised Penal Code. The Court imposed an indeterminate penalty and awarded civil indemnity, actual damages, and loss of earning capacity to the victim’s heirs.