G.R. No. 123172 October 2, 1997
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. FELIX DE GUIA y QUIRINO, accused-appellant.

FACTS

Accused-appellant Felix de Guia y Quirino was convicted of murder by the Regional Trial Court of Quezon City and sentenced to reclusion perpetua. The Information alleged that on October 9, 1992, in Quezon City, accused-appellant, with intent to kill, treachery, abuse of superior strength, and evident premeditation, stabbed Luzon Madarang with a fan knife, causing his death. The prosecution’s version, primarily through eyewitness Greta Amihan Erese, stated that at around midnight, Erese saw accused-appellant and Ricardo Pagadura simultaneously stab Madarang multiple times while he was sleeping on a bench. The location was brightly lit, and Erese was about 15 meters away. The police, responding to reports, found accused-appellant drunk and sleeping in a safehouse, with a bladed weapon and bloodstains on his clothes. The defense presented an alibi, with accused-appellant denying knowledge of the victim and claiming he was asleep at home at the time, and was arrested based on the statements of others. Norberto Saliling, the husband of accused-appellant’s aunt, testified he saw Pagadura stabbing Madarang and that accused-appellant was asleep inside a room during the incident.

ISSUE

The main issues, treated jointly by the Court, revolve around the credibility of prosecution witnesses, the sufficiency of evidence (including whether conviction was based on circumstantial evidence), the weight of defense evidence, and whether guilt was proven beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction with modifications. The Court found no reason to overturn the trial court’s credibility findings, emphasizing the positive and straightforward identification by eyewitness Greta Amihan Erese, who had no motive to falsely testify. The defense of alibi, mainly supported by a relative, could not prevail over this positive identification. However, the Court modified the qualifying circumstance, finding that treachery, not abuse of superior strength, attended the crime because the victim was drunk and sleeping, unable to defend himself, and the attack was sudden and unexpected. Abuse of superior strength was absorbed by treachery. The penalty of reclusion perpetua remained unaffected. The Court also modified the damages: the P50,000.00 civil indemnity and P19,573.00 for funeral expenses were upheld, but moral damages were reduced from P30,000.00 to P20,000.00.