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 Court of Appeals did not err. 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: (1) a person was killed; (2) the accused killed him; and (3) the killing was attended by the qualifying circumstance of treachery. The positive and categorical testimony of eyewitness Maria Reyes, who had no motive to falsely testify, prevailed over the accused’s bare claim of self-defense. For self-defense to prosper, the accused must prove by clear and convincing evidence the elements of unlawful aggression, reasonable necessity of the means employed, and lack of sufficient provocation. Dela Cruz failed to discharge this burden. His claim of being attacked first was uncorroborated and inconsistent with the physical evidence, particularly the location and trajectory of the fatal wound on the victim’s back.

Furthermore, treachery (*alevosia*) was correctly appreciated. The attack was sudden and from behind, without the slightest provocation from the victim, who was unarmed and in no position to defend himself. This method of execution ensured the accomplishment of the killing without risk to the accused. The trial court’s assessment of witness credibility is entitled to great weight and respect, as it is in a better position to observe demeanor. Finding no reversible error in the assailed judgment, the Supreme Court affirmed the conviction.