G.R. No. 219591, February 19, 2018
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee vs. GENERALDO M. CONDINO, Accused-Appellant

FACTS

The accused-appellant, Generaldo M. Condino, was charged with the murder of Isabelo D. Arrabis, a barangay councilor. The prosecution’s evidence established that on September 23, 2002, after a hearing at the Barangay Hall of Lanao, Daanbantayan, Cebu, the victim was seated on a bamboo bench conversing with other officials. Appellant, who had attended the same hearing, calmly approached the group from behind, grabbed the victim’s neck with his left hand, and stabbed him three to four times with a yellowish pointed metal, hitting below the left breast. The victim was pronounced dead on arrival at the hospital due to cardio-respiratory arrest from multiple stab wounds.
In his defense, appellant claimed he acted in self-defense. He testified that as he was exiting the barangay hall, the victim, armed with a knife, suddenly blocked his path. A struggle ensued where they both fell, and he subsequently saw the victim’s chest bleeding. Appellant then fled to Masbate but later surrendered upon his father’s persuasion. The Regional Trial Court found him guilty of murder qualified by treachery and evident premeditation, sentencing him to reclusion perpetua. The Court of Appeals affirmed the conviction but modified the damages awarded and rejected the claim of self-defense.

ISSUE

The core issues were: (1) whether the prosecution proved appellant’s guilt beyond reasonable doubt despite alleged inconsistencies in witness testimonies, and (2) whether the killing was attended by treachery.

RULING

The Supreme Court dismissed the appeal and affirmed the conviction with modifications to the damages. On the first issue, the Court upheld the credibility of the prosecution witnesses. It reiterated the settled doctrine that factual findings of the trial court, which had the direct opportunity to observe witness demeanor and conduct, are accorded the highest respect and are generally binding on appellate courts. The alleged inconsistencies in the testimonies were deemed minor and did not affect the core narrative of a sudden, unprovoked attack. Appellant’s uncorroborated claim of self-defense was rightly rejected for failing to prove the essential element of unlawful aggression.
Regarding treachery, the Court ruled it was duly established. The attack was sudden and unexpected, executed from behind while the unarmed victim was casually talking with others, giving him no opportunity to defend himself or retaliate. The means of execution—grabbing the neck and delivering multiple stab wounds—was deliberately adopted to ensure the attack’s success without risk to the appellant. This manner of attack squarely met the legal criteria for treachery, qualifying the killing as murder. The awards for civil indemnity, moral damages, and exemplary damages were increased to ₱75,000.00 each, actual damages were deleted, and temperate damages of ₱50,000.00 were awarded, all with 6% interest per annum from finality until fully paid.