GR 135857; (June, 2003) (Digest)
G.R. No. 135857 ; June 18, 2003
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. ADRIANO ARCA, Accused-Appellant.
FACTS
Accused-appellant Adriano Arca was charged with the murder of Rommel Godornez. The prosecution presented eyewitnesses Donald Arnulfo and Susan Agda, who testified that on July 16, 1997, in Barangay Maypangdan, Borongan, Eastern Samar, they saw Arca stab the victim, who was on his way to school. SPO1 Reynaldo Afable testified that he responded to the incident, chased Arca who was still holding a bloodied bolo (depang), and effected his arrest. The autopsy report confirmed the victim died from a stab wound penetrating the right lung.
The defense presented a different version. Appellant’s brother, Roberto Arca, testified that it was their cousin, Romeo Arca (“Mano Romy”), who stabbed the victim during a sudden altercation while appellant was drunk and lying on the ground. Appellant himself denied the accusation, claiming he did not know the victim or the prosecution witnesses and was merely a bystander.
ISSUE
Whether the guilt of accused-appellant Adriano Arca for the crime of murder was proven beyond reasonable doubt.
RULING
Yes, the Supreme Court affirmed appellant’s conviction for murder but modified the penalty to reclusion perpetua. The Court found the testimonies of the prosecution witnesses credible, consistent, and straightforward. They positively identified Arca as the assailant who attacked the unsuspecting victim from behind, demonstrating treachery (alevosia). The defense of denial and frame-up, largely anchored on the testimony of appellant’s minor brother, was weak and self-serving. The trial court’s assessment of witness credibility is accorded great respect, as it is in a better position to observe demeanor.
The qualifying circumstance of treachery was properly appreciated. The attack was sudden and from behind, ensuring the victim had no opportunity to defend himself. However, the Court found no sufficient evidence for evident premeditation. Consequently, the penalty was reduced from death to reclusion perpetua, in accordance with prevailing law. The Court also modified the damages awarded, ordering appellant to pay the victim’s heirs P50,000 as civil indemnity, P50,000 as moral damages, and P15,000 as temperate damages.