G.R. No. 126097 February 8, 2000
People of the Philippines vs. Cornelia Suelto

FACTS

The accused-appellant, Cornelia Suelto, was convicted of murder for the killing of Isabel Ruales. The prosecution’s case relied on the eyewitness accounts of Milyn Ruales, a nine-year-old child, and Tomas Rama, a 70-year-old man. They testified that on November 8, 1992, in Barangay Cancawas, San Jose, Negros Oriental, they were part of a group walking home from the town proper. After resting at a bamboo grove where Suelto was present, the group resumed their journey. Milyn, walking behind Suelto and the victim, witnessed Suelto suddenly draw a knife, push aside a basket the victim was carrying, and stab her twice. Tomas, walking ahead, heard shouts, turned, and saw Suelto in the act of stabbing the victim with a hunting knife. The victim died from multiple stab wounds.
The defense presented an alibi, claiming Suelto was in a different barangay attending a birthday party at the time of the crime. She and her witnesses testified she only learned of the killing the following day. The trial court found the prosecution witnesses credible and convicted Suelto of murder qualified by treachery, sentencing her to reclusion perpetua and ordering her to pay damages.

ISSUE

The core issue is whether the trial court erred in convicting the accused-appellant of murder based on the testimonies of the prosecution witnesses and in appreciating the qualifying circumstance of treachery.

RULING

The Supreme Court affirmed the conviction for murder but modified the damages. The Court upheld the credibility of the eyewitnesses, Milyn Ruales and Tomas Rama. Their testimonies were consistent, detailed, and corroborated each other on material points. The Court found no improper motive for them to falsely accuse Suelto. Their testimonies positively identified Suelto as the perpetrator. The defense of alibi was rightly rejected as it was not physically impossible for Suelto to have been at the crime scene, and it was substantially weakened by the positive identification.
The Court agreed that treachery was present. The attack was sudden and unexpected, employing means that deprived the victim of any opportunity to defend herself. The victim was stabbed from behind while walking, with the basket she was carrying being pushed aside to expose her. This manner of execution ensured the assailant’s safety from any retaliation. However, the Court correctly found that evident premeditation was not proven, as the prosecution failed to establish the requisite elements of planning and reflection.
Regarding damages, the award of actual damages was deleted for lack of receipted proof. The indemnity for death was sustained at P50,000.00, and moral damages were increased to P50,000.00 in line with prevailing jurisprudence. The decision of the trial court was thus affirmed with these modifications.