GR 183706; (April, 2012) (Digest)
G.R. No. 183706; April 25, 2012
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. SAMSON ESCLETO, Accused-Appellant.
FACTS
Accused-appellant Samson Escleto was charged with murder for stabbing Alfredo Marchan to death on November 4, 1999. The prosecution presented eyewitnesses Merly Marchan (the victim’s widow) and barangay tanod Benjamin Austria. Their testimonies established that after a birthday party, Escleto, while drinking with Austria at his house, called out to the victim who was passing by. When Alfredo dismounted and approached, Escleto suddenly stabbed him in the chest without any provocation or prior altercation, after which Escleto fled. The postmortem examination confirmed the fatal stab wound. The defense presented a contrary version, claiming that the victim was the aggressor and that it was Benjamin Austria who accidentally stabbed Alfredo during a struggle. The Regional Trial Court convicted Escleto of murder, a decision affirmed by the Court of Appeals.
ISSUE
Whether the Court of Appeals erred in affirming the conviction of the accused-appellant for the crime of murder, qualified by treachery.
RULING
The Supreme Court affirmed the conviction. The Court upheld the factual findings of the lower courts, giving great weight to the clear, consistent, and credible testimonies of the prosecution eyewitnesses, which were found to be more reliable than the self-serving and uncorroborated denial of the accused. On the legal qualification of the crime, the Court ruled that treachery (alevosia) was duly established. The attack was sudden and unexpected, executed in a manner that deprived the victim of any opportunity to defend himself or retaliate. The victim was unarmed and was called to approach under the pretense of a conversation, with no prior heated argument that could have forewarned him of the impending assault. This method of attack directly and specifically ensured the execution of the crime without risk to the assailant. The crime is therefore murder under Article 248 of the Revised Penal Code. The penalty of reclusion perpetua was correctly imposed. The Court modified the awarded damages, increasing civil indemnity to ₱75,000.00 and awarding ₱30,000.00 as exemplary damages and ₱25,000.00 as temperate damages, in addition to moral damages, all with legal interest.