G.R. No. 123456, *People of the Philippines v. Juan Dela Cruz*, January 1, 2023

FACTS:
Accused-appellant Juan Dela Cruz was charged with the crime of Murder for the fatal stabbing of Pedro Santos. The prosecution presented eyewitness Maria Reyes, who testified that she saw Dela Cruz, without any provocation, stab Santos from behind. The defense interposed self-defense, claiming that Santos attacked Dela Cruz first with a bladed weapon. The Regional Trial Court convicted Dela Cruz of Murder, qualified by treachery, and sentenced him to *reclusion perpetua*. The Court of Appeals affirmed the conviction. Dela Cruz appealed to the Supreme Court, arguing that the prosecution failed to prove his guilt beyond reasonable doubt and that the qualifying circumstance of treachery was not established.

ISSUE

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

RULING

NO. The Supreme Court DENIED the appeal and AFFIRMED the conviction of Juan Dela Cruz for Murder.

The Court held that all the elements of Murder under Article 248 of the Revised Penal Code were present. The prosecution successfully proved the killing of Pedro Santos, that it was committed by the accused, and that it was attended by the qualifying circumstance of treachery (*alevosia*). Treachery exists when the offender employs means, methods, or forms in the execution of the crime which tend directly and specially to ensure its execution, without risk to himself arising from the defense which the offended party might make. The eyewitness account, found credible by the trial court, clearly established that the attack was sudden, from behind, and gave the victim no opportunity to defend himself. The claim of self-defense failed because the essential element of unlawful aggression on the part of the victim was not proven by clear and convincing evidence. The trial court’s assessment of witness credibility is entitled to great weight and respect. Thus, the guilt of the accused-appellant was proven beyond reasonable doubt.