G.R. No. 153248; March 25, 2004
PEOPLE OF THE PHILIPPINES, appellee, vs. JESUS MORILES, JR. y QUEBEC, appellant.

FACTS

On March 13, 1994, following a benefit dance in Capoocan, Leyte, Gary Basco was stabbed to death. Prosecution eyewitness Francisco Dadis, Jr. testified that he and the victim were walking beside a river when appellant Jesus Moriles, Jr., a neighbor familiar to Dadis, suddenly appeared from behind and stabbed Basco once in the chest. The attack was swift, with the weapon (a pisao) kept in line with the appellant’s arm until the moment of the stabbing, and the scene was illuminated by a nearby street lamp. The postmortem examination confirmed death was due to a stab wound causing severe hemorrhage.
For his defense, appellant interposed alibi and denial. He claimed he was drinking at a nearby house from the end of the dance until 5:00 a.m. and was not at the crime scene. The trial court found the prosecution’s evidence credible and convicted appellant of Murder qualified by treachery, sentencing him to death and ordering him to pay damages. The case was elevated to the Supreme Court for automatic review.

ISSUE

The primary issues are: (1) whether the prosecution proved appellant’s guilt beyond reasonable doubt, and (2) whether the qualifying circumstance of treachery was correctly appreciated to justify a conviction for Murder.

RULING

The Supreme Court affirmed the conviction for Murder but modified the penalty to reclusion perpetua and adjusted the damages. The Court upheld the trial court’s assessment of credibility, finding the testimony of eyewitness Dadis clear, consistent, and credible. Dadis had no ill motive to falsely testify and positively identified the appellant, whom he knew well, under adequate illumination. The defense of alibi was correctly rejected as it was not physically impossible for appellant to be at the crime scene, which was merely 30 meters from where he claimed to be.
On the qualifying circumstance, the Court ruled that treachery (alevosia) was duly established. The attack was sudden and from behind, executed in a manner that ensured the victim had no opportunity to defend himself or retaliate. The method of employing a concealed pisao and striking the unarmed and unsuspecting victim directly and fatally in the chest clearly indicated a deliberate adoption of means to accomplish the crime without risk to the assailant. This manner of execution qualified the killing as Murder. However, in line with prevailing jurisprudence, the death penalty was reduced to reclusion perpetua, and damages were modified to P50,000.00 civil indemnity, P50,000.00 moral damages, and P25,000.00 temperate damages.