G.R. No. 123111 ; September 13, 2000
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. JIMMY DAGAMI y MORBOS, accused-appellant.

FACTS

The prosecution established that on May 19, 1994, in Sta. Fe, Leyte, accused-appellant Jimmy Dagami stabbed Ignacio Glorioso. The victim, his brother Paquito, and their cousin had attended a dance. As they were leaving around 1:00 a.m., Ignacio walked ahead toward a motorcycle. Without any warning, Dagami, who was familiar to Paquito, drew a knife and stabbed Ignacio in the stomach. The area was illuminated by a nearby fluorescent lamp, allowing Paquito to clearly witness the attack. The unarmed victim, who was facing away and talking to a tricycle driver, ran but was later found and brought to the hospital where he died.
The defense presented a denial, claiming another individual, Raul Castillo, was the assailant. The Regional Trial Court found Dagami guilty of murder, qualified by treachery, and sentenced him to reclusion perpetua with an indemnity of P50,000. Dagami appealed, challenging the credibility of the eyewitness and the appreciation of treachery.

ISSUE

The core issues were: (1) whether the eyewitness identification of the accused was credible and sufficient for conviction, and (2) whether the killing was attended by treachery to qualify the crime as murder.

RULING

The Supreme Court affirmed the conviction. On the first issue, the Court upheld the trial court’s assessment of Paquito Glorioso’s credibility. His positive identification, made under adequate lighting from a close distance, prevailed over the accused’s bare denial. The witness had no ill motive to falsely testify, and his familiarity with the accused from their adjacent barangays bolstered the reliability of his account. Findings of trial courts on witness credibility are accorded great weight.
On the qualifying circumstance of treachery, the Court agreed with its presence. The legal logic requires that the means of execution were deliberately adopted to ensure the act without risk to the offender from any defense the victim might make. Here, the attack was sudden and unexpected, delivered from behind while the victim was unarmed and preoccupied. This manner of attack deprived Ignacio of any opportunity to defend himself or retaliate, squarely meeting the definition of treachery. The penalty for murder is reclusion perpetua to death. With no modifying circumstances, the lower penalty was correctly imposed. The Court modified the damages, adding P50,000.00 as moral damages to the heirs in addition to the death indemnity.