G.R. No. 223715, June 3, 2019
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. MARCELINO SALTARIN Y TALOSIG, Accused-Appellant

FACTS

Accused-appellant Marcelino Saltarin y Talosig was charged with Murder for the killing of Joval Benitez de Jesus on November 6, 2011, in Manila. The information alleged that with intent to kill, treachery, and evident premeditation, appellant stabbed the victim thrice with a bladed weapon, hitting him once on the chest, causing his death. Appellant pleaded not guilty.
The prosecution presented Gerry Narido, a 15-year-old witness, as its lone eyewitness. Narido testified that he and the victim were outside a junk shop around 11:00 PM when appellant asked for coins. The victim gave some, but refused a second request. Later, while Narido and the victim were seated inside a parked kuliglig, appellant returned, handed a cigarette to the victim, and then suddenly stabbed him in the chest, delivering two more blows that missed. Appellant fled. Narido brought the victim to the hospital, where he died. Narido positively identified appellant in court, stating he clearly saw the stabbing despite the dark because appellant was only an arm’s length away and he was seated right beside the victim. The parties stipulated on the testimonies of the arresting officer, attending doctor, investigating officer, and the victim’s mother, and submitted documentary evidence including the death certificate and police reports.
The defense presented only appellant, who claimed self-defense. He testified that the victim blocked his path, asked for a cigarette and then money, and when he refused, the victim held him, drew a knife, and was joined by four companions, including Narido. Appellant claimed he grappled for the knife, they rolled on the ground, and he then ran home. He was arrested the next day.
The Regional Trial Court found appellant guilty of Murder, sentenced him to reclusion perpetua, and ordered him to pay damages. The Court of Appeals affirmed the conviction with modifications: imposing reclusion perpetua without eligibility for parole and increasing the awards for civil indemnity and moral damages.

ISSUE

Did the Court of Appeals err in affirming appellant’s conviction for Murder, with modification of the penalty and monetary awards?

RULING

No, the Court of Appeals did not err. The Supreme Court affirmed the modified decision of the Court of Appeals.
1. On Positive Identification: The Court upheld the credibility of eyewitness Gerry Narido. His positive and categorical testimony, detailing the sudden stabbing, prevailed over appellant’s bare denial and self-defense claim. The Court found no reason to disbelieve Narido, noting that his proximity to the event (seated beside the victim) and the illumination from a nearby streetlight enabled a clear view, despite the nighttime setting. Minor inconsistencies in his testimony (e.g., not knowing the exact address) did not undermine his core account. Denial and alibi are weak defenses against positive identification.
2. On the Qualifying Circumstance of Treachery: The Court found treachery (alevosia) to be present. The attack was sudden and unexpected, executed in a manner that deprived the victim of any chance to defend himself. Appellant handed a cigarette, creating a false sense of normalcy, then immediately stabbed the unarmed and unsuspecting victim who was seated in a confined space. This ensured the execution of the crime without risk to appellant.
3. On Penalty and Damages: The penalty of reclusion perpetua without eligibility for parole was correctly imposed pursuant to Section 3 of Republic Act No. 9346. The Court affirmed the modified awards: Php75,000.00 as civil indemnity, Php75,000.00 as moral damages, and Php75,000.00 as exemplary damages, in line with prevailing jurisprudence. The award of Php13,500.00 as actual damages (for burial expenses) was sustained. All monetary awards shall earn legal interest at 6% per annum from the finality of the judgment until fully paid.
DISPOSITIVE PORTION:
WHEREFORE, the appeal is DISMISSED. The Decision dated February 26, 2015 of the Court of Appeals is AFFIRMED. Appellant Marcelino Saltarin y Talosig is found GUILTY beyond reasonable doubt of Murder and is sentenced to suffer the penalty of reclusion perpetua without eligibility for parole. He is ordered to pay the heirs of the victim Php13,500.00 as actual damages, Php75,000.00 as civil indemnity, Php75,000.00 as moral damages, and Php75,000.00 as exemplary damages. All amounts shall earn interest at 6% per annum from finality of this decision until fully paid.