GR 169877; (February, 2008) (Digest)
G.R. No. 169877 ; February 14, 2008
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. AMADOR SEGOBRE y QUIJANO, defendant-appellant.
FACTS
The appellant, Amador Segobre, was charged with the murder of Roberto Crescini. The prosecution presented eyewitness Lester Villafaña, who testified that on March 15, 1997, in Antipolo City, he saw appellant standing near an electric post. Appellant then blocked the victim, who was on a bicycle, grabbed his right shoulder, and stabbed him in the chest. Villafaña witnessed this from a distance of about 5.5 meters. The medico-legal expert, Dr. Ma. Cristina Freyra, confirmed the victim died from a single fatal stab wound.
The appellant denied the accusation, presenting an alibi. He claimed he was informed of the victim’s accident and was later arrested while waiting for transportation, after picking up a knife discarded by a boy. He asserted he did not know the victim personally, though their houses were adjacent.
ISSUE
The primary issues are: (1) whether the trial court erred in convicting appellant based on the evidence presented, and (2) whether the qualifying circumstances of treachery and evident premeditation attended the killing.
RULING
The Supreme Court affirmed the conviction for murder but modified the appreciation of qualifying circumstances. The Court upheld the trial court’s assessment of witness credibility, emphasizing that the testimony of a single eyewitness, if positive and credible, is sufficient for conviction. Villafaña’s clear and consistent account, given from a proximate distance, prevailed over the appellant’s weak defenses of denial and alibi, which were not substantiated by clear and convincing evidence.
On the qualifying circumstances, the Court agreed with the Court of Appeals that evident premeditation was not proven, as there was no evidence showing how or when the plan to kill was conceived. However, treachery was correctly appreciated. The attack was sudden and unexpected—the appellant blocked the victim, immediately grabbed him, and delivered a fatal stab without any warning or opportunity for defense. This method of attack deliberately ensured the victim’s inability to retaliate or escape, qualifying the killing as murder.
The penalty of reclusion perpetua was affirmed. The awards for civil indemnity and moral damages were sustained. Additionally, exemplary damages were awarded due to the presence of the aggravating circumstance of treachery.