GR 136790; (March, 2001) (Digest)
G.R. No. 136790 ; March 26, 2001
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. MANUEL GALVEZ y ESTANISLAO, accused-appellant.
FACTS
On the evening of May 9, 1998, at a well-lit fair in Caloocan City, accused-appellant Manuel Galvez, accompanied by four companions, approached the victim Romen Castro, who was playing a game with friends. Without any altercation, Galvez directly stabbed Castro in the back, causing him to fall. The incident was witnessed at close range by Danilo Julia, Loreto Palad, and Alvin Adolfo, who consistently identified Galvez as the assailant. The victim was pronounced dead on arrival at the hospital. The initial police investigation led to Galvez, but he was temporarily released after the victim’s brother, Reynaldo Castro, initially stated he was not the culprit. However, upon being informed by the eyewitnesses present in his house, Reynaldo caused Galvez’s apprehension by a barangay tanod, who then turned him over to the police.
ISSUE
The core issue is whether the prosecution proved the guilt of accused-appellant Manuel Galvez for the crime of Murder beyond reasonable doubt, particularly in light of challenges to witness credibility and the defense of alibi.
RULING
The Supreme Court affirmed the conviction for Murder, qualified by treachery, and modified the damages awarded. The Court found the testimonies of the three eyewitnesses credible, consistent, and categorical. Their positive identification prevailed over the weak defense of alibi, which was not physically impossible as Galvez failed to prove he was at such a distance that he could not have been at the crime scene. The Court held that the attack was treacherous because the victim was unarmed, playing a game, and stabbed suddenly from behind without any opportunity to defend himself. The qualifying circumstance of evident premeditation was, however, correctly disregarded for lack of proof of planning. The award of actual damages was deleted for lack of documentary evidence, but temperate damages were granted in its stead. The indemnity for death was increased to P75,000.00, and moral and exemplary damages were affirmed. The penalty of reclusion perpetua was sustained.