G.R. No. 189580 ; February 9, 2011
PEOPLE OF THE PHILIPPINES, Appellee, vs. ALVIN DEL ROSARIO, Appellant.

FACTS

Appellant Alvin del Rosario was charged with Murder for stabbing Edwin Gelua on December 20, 2004, at about 9:00 p.m. in Brgy. G. del Pilar, Bulan, Sorsogon. The Information alleged that the accused, armed with a knife, with intent to kill and taking advantage of nighttime, with treachery and evident premeditation, attacked and stabbed Edwin Gelua, inflicting mortal wounds that caused his death. Upon arraignment, appellant pleaded not guilty.
The prosecution presented four witnesses. Angelita Gelua, the victim’s wife, testified that on the said date, Edwin was having a drinking spree at their home. When Edwin went out to urinate, appellant suddenly appeared and stabbed him with a machete. Dr. Andrew A. de Castro, the attending physician, testified that the cause of death was “cardio-respiratory arrest, stab wound, and hypovolemic shock,” detailing the extensive internal injuries. He opined the victim was face-to-face with or held from behind by the assailant. Salvador Gelua, the victim’s cousin, corroborated Angelita’s account, stating he heard Edwin shout for help, rushed outside, and saw appellant holding a knife before fleeing. Ruel Garlan testified that after the incident, appellant initially denied but later admitted to the stabbing and surrendered the bladed weapon to him, after which Ruel brought appellant to the police.
The appellant invoked his constitutional right to remain silent and presented no evidence. The Regional Trial Court (RTC) found him guilty beyond reasonable doubt of Murder and sentenced him to Reclusion Perpetua, ordering him to pay damages. The Court of Appeals (CA) affirmed the RTC decision in toto. Appellant appealed to the Supreme Court, adopting his Appellant’s Brief from the CA, arguing that the prosecution failed to prove his guilt beyond reasonable doubt, that the eyewitness accounts were improbable and unreliable, and that his alleged admission and surrender of the weapon without counsel should be inadmissible.

ISSUE

Whether the Court of Appeals erred in affirming the appellant’s conviction for Murder, specifically concerning: (1) the credibility of the prosecution eyewitnesses; (2) the sufficiency of evidence to prove guilt beyond reasonable doubt; and (3) the admissibility of the appellant’s alleged extrajudicial admission and surrender of the murder weapon without the assistance of counsel.

RULING

The Supreme Court denied the appeal and affirmed the appellant’s conviction. The Court held that the findings of the trial court on the credibility of witnesses are entitled to great weight and respect, especially when affirmed by the CA, and found no reason to depart from this rule. The positive identification of the appellant by eyewitnesses Angelita and Salvador Gelua was categorical, consistent, and without any showing of ill motive. Their testimonies were deemed credible and sufficient to establish the appellant’s guilt beyond reasonable doubt. The relationship of the witnesses to the victim does not, by itself, impair their credibility, and it is unnatural for a victim’s relatives to accuse an innocent person. The appellant’s bare denial, unsupported by evidence, cannot prevail over the positive identification. The Court also found that the qualifying circumstance of treachery was present, as the attack was sudden and unexpected, giving the victim no opportunity to defend himself. The Court modified the damages awarded, increasing the civil indemnity and moral damages to Php75,000.00 each and awarding exemplary damages of Php30,000.00 due to the presence of the aggravating circumstance of treachery. The appealed Decision was AFFIRMED with MODIFICATION.