G.R. No. 238171 , June 19, 2019
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee vs. ARNALDO ENRIQUEZ, JR., Accused-Appellant

FACTS

Accused-appellant Arnaldo Enriquez, Jr. was charged with Murder for the killing of Florencio Dela Cruz on December 30, 2006, in Quezon City. The prosecution alleged that Enriquez stabbed the unarmed victim from behind with a bread knife as the victim was exiting his house, inflicting fatal wounds. Prosecution witnesses Luisa and Jessica Tolentino testified they heard moaning, looked out their window, and saw the stabbing incident. The defense interposed denial and alibi, claiming Enriquez was on duty as a security guard at the time.
The Regional Trial Court convicted Enriquez of Murder, qualified by treachery, and sentenced him to reclusion perpetua. The Court of Appeals affirmed the conviction but modified the awarded damages. Enriquez appealed to the Supreme Court, arguing the CA erred in affirming his Murder conviction.

ISSUE

Whether the Court of Appeals erred in affirming Enriquez’s conviction for Murder, specifically in finding that the qualifying circumstance of treachery attended the killing.

RULING

The Supreme Court partially granted the appeal. It affirmed the factual findings of the lower courts regarding Enriquez’s culpability for the killing, upholding the credibility of the eyewitness testimonies and rejecting the defenses of denial and alibi. However, the Court downgraded the crime from Murder to Homicide.
The legal logic centers on the requirement for treachery to be proven as clearly and convincingly as the crime itself. Treachery requires the deliberate adoption of means of execution that ensure the safety of the aggressor from any defense or retaliatory act by the victim, and that such means were deliberate and consciously adopted. The Court found the prosecution’s evidence insufficient to establish these elements. The testimonies merely established that the victim was stabbed from behind while leaving his house. This single fact, without more, does not conclusively prove that Enriquez deliberately employed a specific method to ensure the attack was sudden and without risk to himself. The manner of attack was not detailed with clarity to rule out any possibility of a sudden altercation or that the victim was aware of the impending danger. Consequently, the qualifying circumstance of treachery was not proven beyond reasonable doubt. For the crime of Homicide, the Court imposed an indeterminate penalty 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 modified the damages accordingly.