GR 128072; (February, 1999) (Digest)
G.R. No. 128072 February 19, 1999
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. HENRY BENITO, accused-appellant.
FACTS
The prosecution’s evidence established that on the evening of February 4, 1988, accused-appellant Henry Benito went to his in-laws’ hut in Barangay Sonquil, Sta. Barbara, Pangasinan, looking for his wife. When his mother-in-law, Imelda Albarida, informed him his wife was not there, he became angry and began hitting the wall of the hut. As he left, he encountered the victim, Alberto dela Cruz, who was muttering about the disturbance. Without any word, Benito, who was then side-by-side with the victim, pulled a knife from his waist and stabbed dela Cruz in the chest. Imelda Albarida witnessed the entire incident from her window. The victim died from the stab wound before reaching the hospital.
The defense presented a different version. Benito claimed he went to fetch his wife and, upon being refused by his mother-in-law, left with her. He testified he then saw the victim and another man, Pedro Almazan, engaged in a fistfight. He denied stabbing the victim and alleged that his mother-in-law fabricated the charge due to her ill feelings and meddling in his marital affairs. He admitted leaving for Manila after the incident and was arrested years later.
ISSUE
The core issue is whether the prosecution proved the guilt of the accused for the crime of murder beyond reasonable doubt.
RULING
The Supreme Court affirmed the conviction. The Court found the testimony of eyewitness Imelda Albarida to be credible, straightforward, and consistent. She had a clear view of the incident from her window, illuminated by a kerosene lamp, and positively identified Benito as the assailant. Her relationship to the accused by affinity did not impair her credibility, as the rule that testimony from relatives is received with caution applies to the accused’s relatives, not the victim’s. The defense of denial and alibi cannot prevail over the positive identification by a credible witness. The Court upheld the trial court’s finding of treachery (alevosia), qualifying the killing to murder. The attack was sudden and unexpected, depriving the unarmed victim of any chance to defend himself. The penalty of reclusion perpetua was affirmed. The Court awarded civil indemnity and actual damages but deleted the award for moral damages due to the prosecution’s failure to present evidence to substantiate such a claim.