G.R. No. 212818 . January 25, 2017.
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. GREGORIO QUITA alias “GREG”, Accused-Appellant.

FACTS

Accused-appellant Gregorio Quita, along with Fleno Quita, was charged with Murder for the stabbing death of Roberto Solayao on November 17, 2002, in Parañaque City. The prosecution’s case rested primarily on the eyewitness account of the victim’s father, Paquito Solayao. He testified that while on his way to fetch his son from a drinking session, he saw Gregorio holding Roberto’s hand from behind while Fleno stabbed him. The medico-legal officer confirmed the victim sustained multiple wounds, with one fatal stab wound to the shoulder.
The defense presented an alibi and denial. Gregorio claimed he was at a birthday celebration in the same subdivision on the date of the incident but left after an altercation with a group that included someone named “Berto.” He asserted he was not at the crime scene at 8:30 PM and had no knowledge of the victim. The Regional Trial Court convicted Gregorio of Murder, qualified by treachery, and sentenced him to reclusion perpetua. The Court of Appeals affirmed the conviction but modified the awarded damages.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of the accused-appellant for the crime of Murder.

RULING

The Supreme Court dismissed the appeal and affirmed the conviction with modifications to the civil liability. The Court upheld the factual findings of the lower courts, which are generally binding and conclusive. The positive identification by the eyewitness, Paquito Solayao, who knew the appellant for about a year prior to the incident, prevailed over the appellant’s defense of denial and alibi. Denial, being inherently weak, cannot overcome positive testimony. For alibi to prosper, the accused must prove not only that he was elsewhere when the crime occurred but that it was physically impossible for him to be at the scene. The appellant failed to establish this physical impossibility, as his claimed location was within the same general area.
The Court found the qualifying circumstance of treachery to be present. The attack was sudden and unexpected, depriving the victim of any chance to defend himself, as evidenced by the eyewitness account of the victim being held from behind during the stabbing. However, the Court modified the damages awarded in line with prevailing jurisprudence. Actual damages were reduced to temperate damages due to insufficient receipted expenses, while moral and exemplary damages were increased. The appellant was ordered to pay the heirs of the victim civil indemnity, moral damages, exemplary damages, and temperate damages, all with legal interest.