G.R. No. 130281 ; December 15, 2000
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. FELIX CELESTE, accused-appellant.

FACTS

Accused-appellant Felix Celeste was charged with Murder for the killing of Roy Lique. The prosecution established that Celeste, who had been replaced by Lique as an ice delivery boy, harbored a grudge. On September 19, 1996, Celeste confronted and assaulted Lique at a restaurant, threatening him. The following night, September 20, 1996, eyewitness Angelito Catalan testified that while Lique was driving his pedicab, Celeste blocked its path and grabbed its handlebars. Suddenly, an unidentified companion of Celeste struck Lique from behind on the head with a lead pipe, causing his instantaneous death. The companion fled, while Celeste remained at the scene.

ISSUE

Whether the killing of Roy Lique was attended by treachery, thereby qualifying it to Murder.

RULING

Yes, the killing was Murder qualified by treachery. The Supreme Court affirmed the conviction but modified the penalty to reclusion perpetua. The legal logic centers on the concurrence of the two conditions for treachery: (1) the employment of means of execution that gave the victim no opportunity to defend himself or retaliate, and (2) the deliberate and conscious adoption of such means. The eyewitness account clearly showed that the fatal attack was launched from behind the victim, who was restrained in front by Celeste. This method of attack was sudden and unexpected, ensuring that Lique was unable to put up any defense. The Court found that the manner of execution directly and specifically ensured the execution of the crime without risk to the assailants. Since no aggravating or mitigating circumstances attended the crime, the proper penalty is reclusion perpetua. The Court affirmed the awards of P50,000.00 as civil indemnity and P26,000.00 as actual damages, reduced moral damages to P50,000.00, and deleted the award for exemplary damages.