G.R. No. 124706 February 22, 2000
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. CARLITO EREÑO Y AYSON, accused-appellant.

FACTS

Accused-appellant Carlito Ereño was charged with Murder for the stabbing death of Rosanna Honrubia. The prosecution evidence, primarily from eyewitness Arminggol Teofe, established that on the evening of June 21, 1995, in Navotas, an argument ensued between Ereño and Honrubia over a flashlight. The confrontation escalated, leading Honrubia to move to a nearby area. Ereño followed, and during the argument, he suddenly stood, drew a bladed weapon, and stabbed Honrubia in the back. As Honrubia fled, Ereño chased her around a tricycle, eventually catching her, holding her by the hair, and stabbing her twice in the chest, causing her death. The defense consisted of a denial and alibi, with Ereño claiming he was on a jeepney bound for Monumento at the time of the incident.

ISSUE

The core issue is whether the prosecution proved the guilt of the accused-appellant for the crime of Murder beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction but modified the crime from Murder to Homicide. The Court found the testimony of eyewitness Teofe to be credible, positive, and clear, detailing the entire incident without any ill motive. This testimony sufficiently established that Ereño was the perpetrator. The Court rejected the defense of alibi as weak and unsubstantiated, especially in light of the positive identification. However, the Court disagreed with the trial court’s finding of treachery (alevosia), which qualified the killing to Murder. The evidence showed the attack commenced with a frontal argument that escalated into a heated altercation. The initial stab at the back, while the victim was seated, did not constitute alevosia because it did not indicate a deliberate and conscious adoption of a method of execution that ensured the assailant’s safety from any defense the victim might make. The subsequent chase and frontal stabbings further negated treachery, as they occurred during a pursuit, not in a manner that made the victim defenseless. Absent any qualifying circumstance, the crime is Homicide under Article 249 of the Revised Penal Code. The penalty was reduced to an indeterminate sentence of eight years of prision mayor, as minimum, to fourteen years and eight months of reclusion temporal, as maximum. The award of damages was also modified accordingly.