G.R. No. 175929 , December 16, 2008
People of the Philippines, plaintiff-appellee, vs. Rommel Dela Cruz, accused-appellant.

FACTS

On August 7, 1995, at about 7:00 p.m., Rafael Santarin, Mario Pader, and Manny Viscaya were conversing near the barangay hall on Nadurata St., Caloocan City. The area was illuminated by a fluorescent lamp. Santarin and appellant Rommel Dela Cruz were first cousins. Appellant was standing behind the group, about two meters away. Viscaya briefly left to buy cigarettes and returned. Suddenly, appellant came from behind and stabbed Santarin once in the back. Santarin fell to the ground. Appellant immediately fled. Santarin was brought to the hospital but succumbed to the stab wound, which was 15 centimeters deep and reached his left lung. The weapon was described as a sharp, pointed single-bladed instrument. Appellant evaded arrest but was later apprehended in Aliaga, Nueva Ecija. He was charged with Murder, alleged to have been committed with treachery and evident premeditation. During trial, the prosecution presented eyewitness Viscaya and the medico-legal officer. Appellant denied the accusation, interposing alibi and claiming he was collecting fees at the time and later fled to Cebu due to fear. He alleged that Viscaya testified falsely due to a past misunderstanding. The Regional Trial Court convicted appellant of Murder and sentenced him to reclusion perpetua. The Court of Appeals affirmed the conviction with modifications to the damages awarded.

ISSUE

1. Whether the trial court erred in giving full faith and credence to the prosecution witness’s account.
2. Whether the trial court erred in convicting the accused-appellant despite the alleged failure to prove his guilt beyond reasonable doubt.
3. Assuming guilt, whether the crime committed is only Homicide and not Murder.

RULING

The Supreme Court affirmed the conviction for Murder.
1. The trial court did not err in crediting the prosecution witness’s testimony. The positive identification by eyewitness Manny Viscaya, who had known appellant for 15 years as a neighbor, was clear and credible. The court emphasized that the trial court’s assessment of witness credibility is accorded great respect, as it had the opportunity to observe the witness’s demeanor. Viscaya’s testimony detailed how he saw appellant standing behind them and then suddenly stab the victim. His admission that he did not see the weapon used did not weaken his eyewitness account of the stabbing incident.
2. The trial court did not err in finding guilt beyond reasonable doubt. Appellant’s defenses of denial and alibi cannot prevail over the positive identification by the prosecution witness. Furthermore, appellant’s flight from Caloocan to Cebu immediately after the incident and his evasion of arrest for years were considered indications of guilt.
3. The crime committed is Murder, qualified by treachery (alevosia). The attack was sudden and from behind, without any warning, giving the victim no opportunity to defend himself. The victim was seated and conversing with friends when appellant stabbed him from behind. This manner of execution ensured the commission of the crime without risk to the appellant. The Court found that treachery was sufficiently alleged in the Information and proven during trial. The penalty of reclusion perpetua was affirmed. The Court also sustained the modified awards of damages by the Court of Appeals: P50,000.00 as civil indemnity, P20,900.00 as actual damages, P50,000.00 as moral damages, and P25,000.00 as exemplary damages.