GR 144343; (July, 2004) (Digest)
G.R. No. 144343 ; July 7, 2004
PEOPLE OF THE PHILIPPINES, appellee, vs. RICSON PARRENO y ATIDO and DELBERT QUINDO y PLACENCIA, appellants.
FACTS
The appellants, Ricson Parreno and Delbert Quindo, along with four others, were charged with the murder of Anthony Cruz. The prosecution evidence established that in the early morning of November 2, 1997, in Pasig City, the victim and his friends were walking when they were challenged to a fight by the appellants’ group. The victim’s group attempted to leave, but were chased. Anthony Cruz was eventually cornered by three individuals, including the two appellants. Witness Simplicio Genova, Jr. testified that he saw appellant Parreno, who was standing behind the victim, stab him. The assailants then fled. The victim was brought to the hospital but died shortly thereafter from a stab wound that pierced his left lung.
The appellants denied involvement, presenting alibis. Parreno claimed he was at home, while Quindo asserted he was at a friend’s house. The trial court found the prosecution witnesses credible and convicted the appellants of murder qualified by treachery, sentencing them to reclusion perpetua. The appellants appealed, arguing the prosecution failed to prove their guilt beyond reasonable doubt and that the qualifying circumstance of treachery was not established.
ISSUE
The core issue is whether the guilt of the appellants for the crime of murder was proven beyond reasonable doubt.
RULING
The Supreme Court affirmed the conviction with modifications to the damages. The Court found the testimonies of eyewitnesses Simplicio Genova, Jr. and Frederick Sabangan to be clear, consistent, and credible. Their positive identification of the appellants as the perpetrators prevailed over the weak defenses of alibi and denial, which were not corroborated by clear and convincing evidence. The Court upheld the finding of treachery (alevosia). The attack was sudden and from behind, ensuring that the victim, who was unarmed and surrounded, had no opportunity to defend himself. This method of execution deliberately and consciously adopted by the appellants directly insured the commission of the crime without risk to themselves. The Court modified the award of damages, ordering the appellants to jointly and severally pay the victim’s heirs P50,000.00 as civil indemnity, P50,000.00 as moral damages, P25,000.00 as actual damages, and P25,000.00 as exemplary damages.