GR 171272; (June, 2007) (Digest)
G.R. No. 171272, June 7, 2007
PEOPLE OF THE PHILIPPINES, Appellee, vs. LEOSON DELA CRUZ y ECHECHE, Appellant.
FACTS
On November 20, 1999, appellant Leoson dela Cruz, a former messenger in the law firm of Atty. Pelagio Ricalde, gained entry to the Ricalde residence in Marikina City by using a false ID. He told the Ricaldes’ daughter, Rebecca, that her father had summoned him. Upon meeting Atty. Ricalde in the kitchen, dela Cruz asked for a job recommendation. As Ricalde escorted him out, dela Cruz suddenly and repeatedly stabbed Ricalde with a kitchen knife. Ricalde’s wife, Juliana, intervened, begging dela Cruz to stop. Dela Cruz initially fled but returned to stab Juliana multiple times with a letter opener before being apprehended by subdivision guards.
Juliana Ricalde died from her wounds. Pelagio Ricalde survived after receiving timely medical treatment. Appellant was charged with Murder for Juliana’s death and Frustrated Murder for the attack on Pelagio. The Regional Trial Court convicted him on both counts, a decision affirmed by the Court of Appeals. The case was elevated to the Supreme Court for automatic review.
ISSUE
The core issue is whether the prosecution proved the guilt of the appellant for the crimes of Murder and Frustrated Murder beyond reasonable doubt.
RULING
The Supreme Court affirmed the convictions. The Court found the testimonies of the surviving victim, Pelagio Ricalde, and eyewitness Rebecca Ricalde to be credible, consistent, and sufficient to establish appellant’s guilt beyond reasonable doubt. Their positive identification of appellant as the assailant prevailed over his denial and alibi.
For the killing of Juliana, the qualifying circumstance of treachery was present. The attack was sudden and unexpected, executed in a manner that deprived the unarmed victim of any chance to defend herself, especially as she was pleading for her husband’s life. Evident premeditation was not proven, as the prosecution failed to establish clear evidence of planning or preparation. The crime was thus Murder, qualified by treachery.
For the attack on Pelagio, all acts of execution were performed to consummate the killing, but death did not occur due to the timely medical intervention, a cause independent of the appellant’s will. This constitutes Frustrated Murder. The Court modified the penalties, imposing reclusion perpetua for Murder and an indeterminate prison term for Frustrated Murder. Civil indemnities were awarded, including actual damages, loss of earning capacity for Juliana, and moral damages.