G.R. No. 128629 February 22, 2001
The People of the Philippines, plaintiff-appellee, vs. Camelo Lenantud y Linamin and Joven Burla y Delfin, accused-appellants.

FACTS

Accused-appellants Camelo Lenantud and Joven Burla were charged with murder for the death of Teofilo Tullao. The prosecution’s case rested primarily on the eyewitness account of Maricel Galban, a waitress. She testified that on November 22, 1996, at around 11:30 p.m., she saw appellants holding the victim’s hands while a third accomplice, “Ronnie,” stabbed him. Galban was about six arms-length away from the well-lit scene and knew all individuals involved as customers. The victim struggled before falling, after which Lenantud and Ronnie lifted and then dropped him upon realizing he was dead, fleeing thereafter.
The defense presented a different version, claiming the incident arose from a drinking session that turned into a fight. They alleged that the victim was the initial aggressor who attacked Burla with a knife, and that the fatal wound was inflicted during a struggle for possession of the weapon. The trial court rejected the defense’s claim of self-defense, finding the prosecution’s evidence credible, and convicted appellants of murder qualified by treachery, sentencing them to reclusion perpetua.

ISSUE

Whether the guilt of the accused-appellants for the crime of murder was proven beyond reasonable doubt.

RULING

Yes, the Supreme Court affirmed the conviction. The Court found no reason to disturb the trial court’s assessment of witness credibility, particularly that of eyewitness Maricel Galban. Her testimony was clear, consistent, and credible, given her proximity to the well-lit scene and her familiarity with the parties. The defense of self-defense failed as appellants did not prove the essential elements of unlawful aggression, reasonable necessity of the means employed, and lack of sufficient provocation. The nature and location of the single, fatal stab wound, directed backward and downward into the chest, contradicted a claim of a spontaneous struggle and instead indicated a deliberate attack.
The Court upheld the finding of treachery. The attack was sudden and unexpected, depriving the victim of any chance to defend himself, especially as he was restrained by appellants while being stabbed. This method ensured the execution of the crime without risk to the assailants. The penalty of reclusion perpetua was proper. However, the award of actual damages was modified. While receipts for funeral expenses were lacking, the widow’s itemized testimony constituted sufficient proof under jurisprudence, warranting an award of P144,770.00 as actual damages, plus P150,000.00 as civil indemnity.