GR 207389; (February, 2016) (Digest)
G.R. No. 207389 . February 17, 2016. PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. FEDERICO DE LA CRUZ y SANTOS, Accused-Appellant.
FACTS
Accused-appellant Federico De La Cruz was charged with Murder for stabbing Corazon Claudio to death on March 27, 2002, in Manila. The prosecution established that in the early morning, while the victim and her live-in partner, Joan, were having breakfast inside their room, appellant suddenly barged in, pulled out a balisong, grabbed Corazon by the neck, and stabbed her in the back. He continued the attack, inflicting multiple stab wounds even as Joan tried to intervene, which resulted in Joan sustaining injuries to her hand. Corazon was declared dead on arrival at the hospital. Prosecution evidence included Joan’s testimony about appellant’s prior threat to kill Corazon due to his suspicion of an affair between Corazon and his wife, the recovery of appellant’s cellphone at the crime scene, and the medico-legal report detailing fatal stab wounds. The defense interposed alibi, claiming appellant was in Orion, Bataan, during the incident.
ISSUE
Whether the Court of Appeals correctly affirmed appellant’s conviction for Murder qualified by treachery.
RULING
The Supreme Court affirmed the conviction. The prosecution successfully proved appellant’s guilt beyond reasonable doubt through the credible and consistent testimony of eyewitness Joan, which was corroborated by physical evidence and the medico-legal findings. The Court found the qualifying circumstance of treachery (alevosia) to be present. The attack was sudden and unexpected, executed in a manner that deprived the unarmed victim of any opportunity to defend herself or repel the assault. The initial stab in the back, delivered without warning, ensured the execution of the crime without risk to the appellant. The defense of alibi was correctly rejected for being weak and unsubstantiated, especially in light of the positive identification by the eyewitness. The Court modified the awarded damages, increasing civil indemnity and moral damages to P75,000.00 each and computing loss of earning capacity as P695,640.00, all with 6% annual interest from finality until fully paid.