G.R. No. 211053 November 29, 2017
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee vs. SEGFRED L. OROZCO, MANUEL D. OSIR, and ALBERTO B. MATURAN, Accused; ERNIE N. CASTRO, Accused-appellant

FACTS

Accused-appellant Ernie Castro, along with Segfred Orozco, Manuel Osir, and Alberto Maturan, were charged with Murder for the stabbing death of Julius Joshua Mata on November 15, 1998, at Murillo’s Restaurant in Surigao City. The prosecution’s eyewitness, Susan Lalona, testified that she and the victim were at the restaurant when the four accused, apparently drunk, entered. Orozco initially stabbed Mata from behind. When Mata tried to flee, Maturan and Osir held his arms, enabling Castro to stab him in the chest. The group continued the attack before fleeing. Lalona identified Castro later that night, leading to his arrest. The post-mortem examination revealed multiple stab wounds, with the cause of death being severe blood loss.
During trial, Castro admitted his presence and participation but presented a different narrative. He claimed he was at the jukebox when a commotion erupted. He saw Orozco struggling with a woman (Lalona) and, thinking the victim may have stabbed Orozco, he grabbed a knife and gave chase. He testified that Orozco overtook and stabbed Mata. The Regional Trial Court convicted Castro of Murder, a decision affirmed by the Court of Appeals. Castro appealed to the Supreme Court.

ISSUE

Whether the qualifying circumstance of treachery (alevosia) was proven to elevate the killing from Homicide to Murder.

RULING

Yes, the Supreme Court affirmed the conviction for Murder. The Court found that the qualifying circumstance of treachery was sufficiently established. Treachery exists when the offender employs means, methods, or forms in the execution of the crime that tend directly and specially to ensure its execution, without risk to themselves arising from any defense the victim might make. The prosecution evidence clearly showed a concerted attack where the victim was initially assaulted from behind by Orozco, a sudden and unexpected act that deprived him of any chance to defend himself. When he attempted to escape, his arms were restrained by his other assailants, further ensuring he could not retaliate or evade the subsequent fatal blows delivered by Castro and others. This method of attack, where the victim was subdued and his defense neutralized by the accused acting in concert, squarely constitutes treachery. Castro’s own testimony placed him at the scene, chasing the victim with a knife. His defense of denial could not prevail over the positive and credible identification by the eyewitness. The Court upheld the penalty of reclusion perpetua and the award of damages, with modifications to include interest on the monetary awards.