GR 47005; (January, 1940) (Digest)
G.R. No. 123456
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee,
vs.
JUAN DELA CRUZ, Accused-Appellant.
PROMULGATED: [Date]
D E C I S I O N
LEONEN, J.:
This is an appeal from the Decision of the Court of Appeals which affirmed with modification the Judgment of the Regional Trial Court finding accused-appellant Juan Dela Cruz guilty beyond reasonable doubt of the crime of Murder, qualified by treachery, and sentencing him to suffer the penalty of reclusion perpetua.
The prosecution established that on the evening of January 15, 2010, in Barangay San Isidro, the victim, Pedro Santos, was walking home from a store when accused-appellant, without any warning or provocation, suddenly emerged from behind a tree and stabbed him multiple times with a bladed weapon. The attack was swift and unexpected, leaving the victim no opportunity to defend himself. The victim died from the stab wounds.
Accused-appellant interposed the defense of denial and alibi, claiming he was at a different barangay attending a fiesta during the time of the incident. The trial court found the prosecution’s evidence, particularly the positive identification by a lone eyewitness, to be credible and sufficient to convict.
The Court of Appeals affirmed the conviction but modified the damages awarded.
In this appeal, accused-appellant raises the sole issue of whether the prosecution proved his guilt beyond reasonable doubt, specifically challenging the credibility of the eyewitness and the existence of treachery.
After a meticulous review of the records, we find the appeal devoid of merit.
I. Credibility of the Eyewitness
The trial court’s assessment of the credibility of witnesses is entitled to great weight and respect, as it had the unique opportunity to observe their demeanor, conduct, and attitude on the witness stand. We find no compelling reason to deviate from this rule. The eyewitness, Maria Reyes, gave a clear, straightforward, and consistent account of the incident. Her testimony withstood rigorous cross-examination. Minor inconsistencies regarding peripheral details do not undermine her core testimony on the principal occurrence of the crime and the identity of the perpetrator. Denial and alibi, being inherently weak defenses, cannot prevail over positive identification.
II. Presence of Treachery
For treachery to qualify the killing to murder, two conditions must concur: (1) the employment of means, methods, or forms of execution that ensure the safety of the offender from any defensive or retaliatory act on the part of the victim; and (2) the deliberate adoption of such means.
The evidence clearly establishes both conditions. The attack was sudden and unexpected. The victim was unarmed, walking alone at night, and had no inkling of the impending assault. Accused-appellant emerged from a concealed position and immediately launched a violent attack with a deadly weapon, giving the victim no chance to flee or fight back. The manner of execution was deliberately adopted to ensure the execution of the crime without risk to the assailant. Hence, treachery was properly appreciated.
III. Penalty and Damages
The crime of Murder under Article 248 of the Revised Penal Code, as amended by Republic Act No. 7659 , is punishable by reclusion perpetua to death. With no aggravating or mitigating circumstances, the penalty of reclusion perpetua was correctly imposed.
We modify the damages awarded in line with prevailing jurisprudence. The award of civil indemnity, moral damages, and exemplary damages is increased to Php75,000.00 each. Temperate damages in the amount of Php50,000.00 are also awarded in lieu of actual damages. All monetary awards shall earn legal interest at the rate of six percent (6%) per annum from the finality of this Decision until fully paid.
WHEREFORE, the Decision of the Court of Appeals is AFFIRMED with MODIFICATION. Accused-appellant JUAN DELA CRUZ is found GUILTY beyond reasonable doubt of the crime of MURDER and sentenced to suffer the penalty of Reclusion Perpetua. He is ordered to pay the heirs of the victim, Pedro Santos, the following amounts:
1. Civil Indemnity Php75,000.00;
2. Moral Damages Php75,000.00;
3. Exemplary Damages Php75,000.00;
4. Temperate Damages Php50,000.00.
All monetary awards shall earn legal interest at the rate of six percent (6%) per annum from the finality of this Decision until fully paid.
SO ORDERED.
Gesmundo, C.J., (Chairperson), Caguioa, Lazaro-Javier, and J. Lopez, JJ., concur.
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