G.R. No. 190322 , November 26, 2014
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. VIRGILIO AMORA y VISCARRA, Accused-Appellant.

FACTS

On September 12, 2004, around 5:45 p.m., Anselmo Benito, Aurelio Amora, and the victim Romeo Gibaga were walking to Sampol Market in San Jose Del Monte City, Bulacan. Maricris Alidon and her son were walking about four meters behind them. They saw the accused-appellant, Virgilio Amora, in his store by the street. Suddenly, appellant rushed towards them and stabbed Romeo twice—once in the chest and once in the abdomen. The attack was sudden and unexpected, catching Romeo and the witnesses by surprise. Romeo fell, and appellant fled. Aurelio gave chase but failed to catch him. Romeo was brought to the hospital and died three days later. Before his death, he identified appellant as his assailant to his wife, Linda Gibaga. Dr. Felimon C. Porciuncula, Jr., the medico-legal officer, testified that the two fatal stab wounds—one piercing the heart and the other the pancreas and small intestines—caused Romeo’s death. Appellant was charged with Murder. He pleaded not guilty, claiming he was at a construction site 8-9 kilometers away at the time and was falsely implicated because he had refused a request for money to buy shabu from prosecution witness Anselmo Benito the previous day.

ISSUE

1. Whether the prosecution proved the guilt of the accused-appellant beyond reasonable doubt.
2. Whether the qualifying circumstance of treachery was duly established.

RULING

The Supreme Court DENIED the appeal and AFFIRMED the conviction for Murder with modifications to the damages awarded.
1. On the proof of guilt beyond reasonable doubt: The Court upheld the positive identification of appellant by three eyewitnesses—Maricris Alidon, Anselmo Benito, and Aurelio Amora. Their testimonies were found straightforward, credible, and consistent. The Court rejected appellant’s defenses of alibi and alleged improper motive of the witnesses (refusal to give money for shabu), noting that positive identification prevails over self-serving denials and that alibi is inherently weak. The claim that darkness and witness Aurelio’s drunkenness impaired identification was unpersuasive, as the collective testimonies of multiple witnesses reliably established appellant’s identity as the perpetrator.
2. On the presence of treachery: The Court ruled that treachery (alevosia) was properly appreciated. The attack was sudden and unexpected, executed in a manner that deprived the unarmed victim of any chance to defend himself or repel the assault. The Court emphasized that treachery can exist even in a frontal attack if it is sudden and on an unarmed, unsuspecting victim. The swift and unprovoked stabbing ensured the execution of the crime without risk to the appellant from any defense the victim might make.
DISPOSITIVE PORTION:
The Court AFFIRMED the conviction for Murder and the penalty of reclusion perpetua without eligibility for parole. The awards for civil liability were MODIFIED as follows:
1. Civil indemnity increased from ₱50,000.00 to ₱75,000.00.
2. Moral damages of ₱50,000.00.
3. Exemplary damages of ₱30,000.00.
4. Actual damages of ₱16,770.69 (medical expenses) and ₱35,000.00 (funeral expenses).
5. The award of ₱25,000.00 as temperate damages was DELETED.
6. All monetary awards shall earn legal interest at 6% per annum from the date of finality of the Resolution until fully paid.