G.R. No. 127127 July 30, 1998
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. EUFROCENIO LACESTE, CIPRIANO LACESTE, RIZALINO LACESTE, EDDIE BAUSON, ARTHUR BAUSON, BONIFACIO SORIANO, and JOHN DOE, accused, EUFROCENIO LACESTE, accused-appellant.

FACTS

On April 9, 1995, at around 9:30 p.m., Orlando Dispo, Bernardo Raboy, Rufo Narvas, Sr., and Edwin Genese were having a drinking spree in front of a store in San Fabian, Pangasinan. A tricycle driven by Bonifacio Soriano arrived, from which accused Eufrocenio Laceste, Cipriano Laceste, Rizalino Laceste, Eddie Bauson, and Arthur Bauson alighted. Cipriano Laceste, Rizalino Laceste, Eddie Bauson, and Arthur Bauson held Rufo Narvas, Sr. by the arms, and Eufrocenio Laceste immediately stabbed him in the abdomen with a fan knife, causing his instantaneous death. The accused then fled on the tricycle. Eufrocenio Laceste and his brother Cipriano were arrested on May 1, 1996, after having gone into hiding. They were charged with Murder. After a joint trial, the Regional Trial Court convicted Eufrocenio Laceste of Murder qualified by treachery and sentenced him to death. It acquitted Cipriano Laceste, finding no proof of conspiracy. The defense version claimed that a fight ensued after the victim and his companion threw stones and uttered insults, and that it was Eddie Bauson, not Eufrocenio, who stabbed the victim after a struggle over a knife.

ISSUE

1. Whether the trial court erred in giving full credence to the testimonies of the prosecution witnesses and disregarding the defense theory.
2. Whether the trial court erred in finding accused-appellant Eufrocenio Laceste guilty beyond reasonable doubt of Murder.
3. Whether the trial court erred in appreciating the qualifying circumstance of treachery.

RULING

The Supreme Court AFFIRMED the conviction for Murder but MODIFIED the penalty and the award of damages.
1. The trial court did not err in crediting the prosecution witnesses. Their testimonies were straightforward, firm, and showed no signs of fabrication. The Court held that the witnesses’ failure to aid the victim or make an outcry does not render their testimonies unbelievable, as there is no standard behavioral response to a startling event. The defense witnesses’ testimonies were found biased and uncorroborated. The flight of the accused-appellant after the incident further indicated guilt.
2. The prosecution evidence sufficiently proved accused-appellant’s guilt beyond reasonable doubt. The positive identification by two eyewitnesses prevailed over the denial and alibi of the defense. The claim that Eddie Bauson was the stabber, based on the testimony of the accused’s mother and sister-in-law, was not credible.
3. The qualifying circumstance of treachery was correctly appreciated. The attack was sudden and unexpected, executed in a manner that deprived the victim of any chance to defend himself. The victim was unarmed, held by four companions of the accused, and stabbed without any provocation. The fact that there was only one stab wound and that the victim and assailant were facing each other does not negate treachery when the attack was swift and deliberate.
The penalty was modified from death to reclusion perpetua because the information did not allege any aggravating circumstance that would justify the imposition of the death penalty under Republic Act No. 7659 . The award of damages was modified: P50,000 as civil indemnity and P60,000 as actual damages (which the defense admitted during trial), in lieu of the trial court’s award of P100,000 for various damages.