G.R. No. 129688; April 2, 2002
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. MAMERTO OBOSA, accused-appellant.

FACTS

On July 7, 1995, in Caloocan City, accused-appellant Mamerto Obosa, the victim’s attorney-in-fact and driver, visited Leonarda Lora at her apartment. Witnesses heard Obosa threaten Lora, demanding money. They were later seen entering a separate apartment unit. A neighbor heard a female shout “Huwag!” and saw Obosa dragging Lora. Obosa was later seen leaving the apartment. The victim was subsequently found dead inside, having sustained multiple fatal stab wounds. The prosecution established that Obosa owed the victim a significant debt and that the taxi he drove was mortgaged to a bank under her name. After the incident, Obosa fled and went into hiding.
Obosa denied the accusation, presenting an alibi. He claimed he had delivered a document to Lora earlier and left. He stated he was later informed of the stabbing, reported it to the police, and accompanied them to the scene. The Regional Trial Court found him guilty of murder qualified by treachery and sentenced him to death. The case was elevated to the Supreme Court for automatic review.

ISSUE

The core issue is whether the guilt of the accused for the crime of murder was proven beyond reasonable doubt.

RULING

Yes, the Supreme Court affirmed the conviction but modified the penalty and damages. The Court found the prosecution’s evidence, particularly the credible and consistent testimonies of eyewitness Jenny Lora and neighbor Benjamin Marquez, sufficient to establish Obosa’s guilt beyond reasonable doubt. Their positive identification, corroborated by the physical evidence and Obosa’s motive arising from his debt, convincingly points to him as the perpetrator. The Court rejected Obosa’s alibi and denial as weak defenses, which cannot prevail over positive identification. His flight after the incident further indicated guilt.
The killing was correctly qualified as murder due to the presence of treachery. The attack was sudden and unexpected, as the victim was dragged and assaulted inside her own home, depriving her of any chance to defend herself. However, the penalty was reduced from death to reclusion perpetua because the information alleged but did not prove the aggravating circumstance of evident premeditation. With treachery as the sole qualifying circumstance and no other aggravating factors, the proper penalty is reclusion perpetua. The awards for damages were also modified. Civil indemnity of ₱50,000.00 is affirmed. Moral damages were reduced to ₱50,000.00, while the awards for actual damages (funeral expenses) and attorney’s fees were deleted for lack of evidentiary support.