GR 126028; (March, 2003) (Digest)
G.R. No. 126028 ; March 14, 2003
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. EXPEDITO ALFON, accused-appellant.
FACTS
The prosecution established that on February 18, 1993, in Barangay Oring, Caramoan, Camarines Sur, accused-appellant Expedito Alfon fatally stabbed Tomas Alferez. Eyewitnesses Vicente Eusebio and Manuel Rayoso testified that they saw Alfon following the victim. Without warning, Alfon suddenly stabbed Alferez twice with a balisong knife, hitting him in the chest. The victim fell, and the appellant fled. Dr. Minerva Aguirre, who conducted the autopsy, confirmed the victim sustained two fatal stab wounds from a sharp instrument, causing death due to profuse hemorrhage.
The defense presented a contrary version. Alfon claimed he was waylaid by the victim and his brother, Rodolfo Alferez. A scuffle ensued, and during the fight, Rodolfo attempted to stab him but instead accidentally hit and killed his own brother, Tomas. The trial court rejected this defense, finding the testimonies of the prosecution eyewitnesses credible and consistent. It convicted Alfon of Murder qualified by treachery and sentenced him to reclusion perpetua.
ISSUE
The core issues were: (1) whether the prosecution proved Alfon’s guilt beyond reasonable doubt; (2) whether treachery attended the killing to qualify it as Murder; and (3) the propriety of the awarded damages.
RULING
The Supreme Court affirmed the conviction but modified the damages. The Court upheld the trial court’s assessment of the eyewitnesses’ credibility, noting no ill motive was shown for them to falsely testify against the appellant. Their positive identification prevailed over Alfon’s bare denial and uncorroborated alternative narrative. The Court also found treachery present. The attack was sudden and from behind, ensuring the victim had no opportunity to defend himself. This method of execution deliberately and directly ensured the killing without risk to the assailant.
Regarding damages, the Court sustained the P50,000 civil indemnity. However, it deleted the P24,220 actual damages due to lack of sufficient proof, such as receipts. In its place, the Court awarded P25,000 as temperate damages, acknowledging the heirs incurred funeral expenses though the exact amount was unproven. Exemplary damages of P25,000 were also awarded due to the presence of treachery. The penalty of reclusion perpetua was affirmed as correct under the law applicable at the time of the crime’s commission.