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 forensic evidence. The defense interposed alibi and denial, claiming Dela Cruz was in a different city at the time of the incident. 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 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 established.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of accused-appellant for the crime of Murder.

RULING

No. The Supreme Court DENIED the appeal and AFFIRMED the Decision of the Court of Appeals with MODIFICATION as to damages.

The Court held that all the elements of Murder under Article 248 of the Revised Penal Code were proven beyond reasonable doubt. The eyewitness account was credible, consistent, and positive, prevailing over the weak defenses of alibi and denial. The forensic evidence corroborated the testimony. However, the Court found that treachery (*alevosia*) was not sufficiently established. The prosecution failed to prove that the accused employed means, methods, or forms in the execution of the crime which tended directly and specially to ensure its execution without risk to himself arising from the defense which the offended party might make. The attack was sudden, but the evidence did not show that the victim was utterly deprived of any opportunity to defend himself or retaliate. Thus, the crime is properly Homicide, not Murder.

Accused-appellant Juan Dela Cruz is found GUILTY of Homicide under Article 249 of the Revised Penal Code and is sentenced to an indeterminate penalty of eight (8) years and one (1) day of *prision mayor* as minimum, to fourteen (14) years, eight (8) months and one (1) day of *reclusion temporal* as maximum. He is ordered to pay the heirs of the victim civil indemnity, moral damages, and temperate damages, all with legal interest.