GR No. 123456, January 30, 2024
People of the Philippines v. Juan Dela Cruz

FACTS

Accused-appellant Juan Dela Cruz was charged with the crime of Murder for the fatal stabbing of Pedro Santos. The prosecution presented eyewitness testimony and circumstantial evidence. The Regional Trial Court (RTC) convicted Dela Cruz of Murder qualified by treachery and sentenced him to reclusion perpetua. On appeal, the Court of Appeals (CA) affirmed the RTC decision in toto. Dela Cruz now appeals before the Supreme Court, arguing that the prosecution failed to prove his guilt beyond reasonable doubt and that the qualifying circumstance of treachery was not sufficiently 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 affirmed the conviction but modified the penalty.

The Court held that all the elements of Murder under Article 248 of the Revised Penal Code were present. The prosecution evidence, particularly the credible and consistent testimony of the eyewitness who had no motive to falsely testify, established that the accused-appellant was the perpetrator. The killing was attended by the qualifying circumstance of treachery (*alevosia*). The evidence showed that the attack was sudden and unexpected, employing means that deprived the unarmed victim of any opportunity to defend himself or retaliate. The manner of execution, a swift stab from behind without any provocation at that instant, directly and specifically ensured the execution of the crime without risk to the assailant.

However, in line with prevailing jurisprudence and Republic Act No. 9346, the Supreme Court modified the penalty. The indeterminate sentence of *reclusion perpetua* without parole is hereby imposed. The Court also affirmed the awards of civil indemnity, moral damages, and exemplary damages to the heirs of the victim, with interest at the legal rate of six percent (6%) per annum from the finality of this judgment until fully paid.