G.R. No. 180915 ; August 9, 2010
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. CHARLIE NAZARENO Y MELANIOS, Accused-Appellant.

FACTS

The prosecution’s case, primarily through eyewitness Jericho Capanas, established that at around 3:30 a.m. on September 23, 2001, in Manila, appellant Charlie Nazareno was causing a disturbance outside his neighbor’s house. He kicked open the door of Romeo de Guzman’s house, and when the victim stood up behind it, appellant immediately grabbed him by the hair and stabbed him in the chest with a bladed weapon. Capanas, who was less than an arm’s length away due to the adjacent doors of their houses, witnessed the attack. The victim was brought to the hospital where he identified appellant as his assailant before succumbing to his wounds. Appellant was arrested nearby holding a bloodied bladed weapon.
Appellant presented a contrary version, claiming he and the victim had been drinking together. He testified that the victim became aggressive, pulled his hair, and a struggle over a bladed weapon ensued during which the victim was accidentally wounded. The Regional Trial Court convicted appellant of murder qualified by treachery and sentenced him to reclusion perpetua, a decision affirmed by the Court of Appeals with modifications to the civil damages.

ISSUE

Whether the Court of Appeals erred in affirming appellant’s conviction for murder, specifically concerning the credibility of the eyewitness and the presence of the qualifying circumstance of treachery.

RULING

The Supreme Court affirmed the conviction for murder. The Court found no merit in appellant’s challenge to the eyewitness’s credibility. The alleged inconsistencies in Jericho Capanas’s testimony—regarding the number of drunk men and his precise location during the victim’s dying declaration—were minor and did not pertain to the core fact of the stabbing, which he clearly and consistently described from a vantage point less than an arm’s length away. The Court upheld the trial court’s assessment of Capanas’s credibility, which is accorded great respect.
Furthermore, the Court ruled that treachery was correctly appreciated. The attack was sudden and unexpected. The victim, who had just been awakened and was standing behind his door, was given no opportunity to defend himself or repel the assault when appellant immediately grabbed his hair and delivered the fatal chest thrust. The manner of execution deliberately ensured the victim’s helplessness. The Court also noted appellant’s offer of compromise, contained in a letter to the victim’s brother asking for forgiveness, which is admissible as an implied admission of guilt. The penalty of reclusion perpetua was affirmed, and the awards for civil indemnity, moral damages, and exemplary damages were sustained.