G.R. No. 173197 ; April 24, 2007
People of the Philippines, Plaintiff-Appellee, vs. Roger De Guzman y Lauchangco, Accused-Appellant.

FACTS

On October 15, 2000, in San Miguel, Bulacan, accused-appellant Roger De Guzman was charged with the murder of his 67-year-old aunt, Marcosa Lauchangco. The prosecution presented eyewitness Michael Lauchangco, the victim’s nephew and appellant’s cousin, who testified that he was sitting in front of the victim’s store when he saw appellant enter and suddenly bash the victim on the back of her head with a steel pipe. After she fell, appellant struck her twice more. Michael ran to report the incident. The victim died from cerebral hemorrhage due to severe head injury. Appellant’s own brother, Robin, reported the crime to the police.
The defense presented a different narrative. Appellant claimed that a helper named Rodolfo Boncales was the actual perpetrator. He testified that Boncales had earlier planned a robbery of the store and, on the day of the incident, struck the victim after appellant refused to participate. Appellant’s brothers, Roberto and Robin, corroborated parts of his story, claiming Boncales borrowed the lead pipe and was the assailant. However, they admitted that Michael had identified appellant as the attacker at the scene.

ISSUE

Whether the Court of Appeals erred in affirming the trial court’s conviction of appellant for murder qualified by treachery.

RULING

The Supreme Court affirmed the conviction. The Court upheld the credibility of the prosecution eyewitness, Michael Lauchangco. His positive and categorical identification of appellant as the one who delivered the fatal blows prevailed over the denial and alibi of the accused. The defense’s theory implicating Boncales was weakened by the brothers’ own testimonies, which contained inconsistencies and did not convincingly rebut Michael’s account. The claim that Michael was coerced to testify was unsupported by evidence.
The Court also affirmed the presence of treachery, which qualified the killing as murder. The attack was sudden and unexpected, executed in a manner that deprived the elderly and unarmed victim of any opportunity to defend herself. Appellant employed a steel pipe and struck the victim from behind while she was preoccupied inside her store, ensuring the execution of the attack without risk to himself. The penalty of reclusion perpetua was proper. The Court modified the damages, affirming the awards of civil indemnity and moral damages and adding exemplary damages of ₱25,000.00 because the qualifying circumstance of treachery was proven.