G.R. No. 144318 . April 3, 2002.
People of the Philippines, plaintiff-appellee, vs. Jonathan Anacan y Jalandoni, accused-appellant.

FACTS

Accused-appellant Jonathan Anacan was convicted of murder by the Regional Trial Court for the death of Henry Villanueva. The incident occurred in the early morning of April 14, 1997, after Villanueva and his cousin, Ricky Lejano, had been drinking at the Batik Restaurant. They had invited a lady guest relations officer, who was the girlfriend of the restaurant’s disc jockey, Randy Pacolba, to join them. As Villanueva and Lejano were about to leave, Randy Pacolba, accused-appellant Jonathan Anacan, and a certain Galman mauled Villanueva inside the restaurant. Villanueva rushed out but was pursued by Anacan, who overtook and repeatedly stabbed him. Villanueva later died from his wounds. An Information for murder was filed against Anacan. Randy Pacolba was also charged but remained at large. Anacan denied the accusation, claiming he was at the restaurant but left during a commotion and went to his workplace. The trial court found the eyewitness account of Ricky Lejano credible and convicted Anacan of murder, sentencing him to reclusion perpetua and ordering him to pay damages.

ISSUE

The primary issues resolved by the Supreme Court were: (1) whether the eyewitness identification of the accused-appellant was reliable; (2) whether inconsistencies in the witness’s testimony affected his credibility; (3) whether the defense of alibi should be credited; and (4) whether the qualifying circumstance of treachery was proven to justify a conviction for murder.

RULING

The Supreme Court MODIFIED the trial court’s decision. It upheld the conviction but found the qualifying circumstance of treachery not proven beyond reasonable doubt. The Court ruled as follows:
1. The positive identification by eyewitness Ricky Lejano was reliable. No law requires a police line-up for proper identification. Lejano had prior familiarity with Anacan, the incident occurred in a well-lighted area, and he had a clear view from a distance of about twelve meters. No ill motive was shown for Lejano to testify falsely.
2. The inconsistencies in Lejano’s testimony (e.g., the number of stab wounds and the exact date of death) pertained to collateral matters and did not affect the core of his account. Such minor inconsistencies even enhanced his credibility by showing his testimony was not rehearsed.
3. The defense of alibi failed. For alibi to prosper, it must be shown that it was physically impossible for the accused to be at the crime scene. Anacan himself admitted he was at the Batik Restaurant when the crime occurred.
4. The qualifying circumstance of treachery was not established. The prosecution failed to provide details on how the attack was executed. The mere fact that the victim was drunk and unarmed did not automatically constitute treachery. The elements—that the means of execution gave the victim no opportunity to defend himself and was deliberately adopted—were not proven beyond reasonable doubt.
Consequently, the Court found accused-appellant guilty of HOMICIDE, not murder. He was sentenced to an indeterminate penalty of six (6) years, eight (8) months, and ten (10) days of prision mayor minimum as minimum, to fourteen (14) years, ten (10) months, and twenty (20) days of reclusion temporal medium as maximum. The award of damages was modified: actual damages increased to P97,782.55; moral damages reduced to P50,000.00; and civil indemnity of P50,000.00 was affirmed.