G.R. No. 232493, June 19, 2019
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee vs. CESAR VILLAMOR CORPIN @ “BAY”, Accused-Appellant

FACTS

Accused-appellant Cesar Villamor Corpin was charged with Murder for hacking Paulo Pineda with a butcher’s knife at the Las Piñas Public Market. The prosecution presented multiple eyewitnesses, including fellow vendors Helen Raymundo and Marlon Ramos. Their testimonies established that on September 1, 2010, Corpin, a pork vendor, attacked Pineda, a chicken vendor, from behind while the victim was carrying a tray of chicken. The witnesses consistently stated that the attack was sudden, with Pineda having no opportunity to defend himself. The victim sustained a fatal hacking wound to the maxillary zygomatic area, as confirmed by Dr. Ethel Punzalan, and died from hypovolemic shock.
The defense did not deny the act of hacking but claimed it was unintentional. Corpin testified that he and the victim often exchanged jokes, and on that day, he was merely swinging his knife to scare Pineda, who allegedly moved backward, causing the blade to accidentally hit him. The Regional Trial Court convicted Corpin of Murder, qualified by treachery, and sentenced him to reclusion perpetua. The Court of Appeals affirmed this decision in toto.

ISSUE

Whether the qualifying circumstance of treachery was sufficiently proven to convict the accused-appellant of Murder instead of Homicide.

RULING

The Supreme Court partially granted the appeal. It modified the conviction from Murder to Homicide, holding that treachery was not established beyond reasonable doubt. The Court reiterated that for treachery to qualify a killing to murder, two conditions must concur: (1) the employment of means of execution that gives the person attacked no opportunity to defend himself or retaliate, and (2) the deliberate and conscious adoption of such means. The prosecution evidence, while proving a sudden attack from behind, failed to conclusively demonstrate that Corpin consciously and deliberately adopted this method to ensure the execution of the crime without risk to himself.
The Court found that the altercation arose from a history of personal exchanges and jokes between the two vendors. The prosecution did not adequately prove that Corpin had planned or prepared the attack. The suddenness alone, absent clear proof of a deliberate plan to employ a treacherous mode of attack, is insufficient to qualify the crime as Murder. Thus, the killing constituted the lesser crime of Homicide under Article 249 of the Revised Penal Code. The Court imposed an indeterminate sentence of eight years and one day of prision mayor, as minimum, to fourteen years, eight months, and one day of reclusion temporal, as maximum, and ordered the accused to pay the heirs of the victim civil indemnity, moral damages, and temperate damages of ₱50,000.00 each.