G.R. No. L-48548 January 27, 1981
People of the Philippines, plaintiff-appellee, vs. Bienvenido Hinlo y Canalija, defendant-appellant.

FACTS

On the evening of May 8, 1977, in Almanza, Las Piñas, the appellant, Bienvenido Hinlo, was seen by neighbors slapping his wife and threatening to stab anyone who intervened. Saturnina Petilla, who attempted to pacify him, was chased with a knife. Hinlo then proceeded to a nearby house where the victim, Hilarion Martin, and Benjamin Dayuta were resting while fetching water. Without warning, Hinlo entered and stabbed Martin twice in the back and Dayuta once on the arm. Martin died from his wounds. Hinlo fled but was later arrested. The prosecution presented eyewitnesses Dayuta and Petilla, whose testimonies detailed the sudden and unexpected attack.
The defense presented a different version, claiming Hinlo was merely attempting to pacify a quarrel involving one Leodegario Petilla and a group of men, during which he was hit on the head and fled. The trial court found this narrative improbable, noting Hinlo’s failure to seek police help or explain what happened to Leodegario afterward. The court convicted Hinlo of murder, qualified by treachery, and sentenced him to reclusion perpetua.

ISSUE

The core issue is whether the trial court erred in convicting the appellant of murder by giving credence to the testimonies of the prosecution witnesses despite alleged inconsistencies and by rejecting the appellant’s alternative version of events.

RULING

The Supreme Court affirmed the conviction. The Court meticulously addressed the appellant’s claims of inconsistencies in the testimonies of Benjamin Dayuta and Saturnina Petilla. It found that the alleged discrepancies were minor and did not pertain to the central fact of the stabbing. For instance, Petilla not seeing Dayuta’s helper was explained by her vantage point outside a partly opened door. The difference in describing the victim’s position when stabbed was reconciled by considering that the two witnesses could have been describing different moments during the two stab wounds. The Court held that these variances, far from discrediting the witnesses, demonstrated they were not rehearsed and reflected honest recollections.
The Court also found the appellant’s defense inherently unbelievable. His claim that he approached an armed confrontation merely to pacify the parties, only to be struck and then flee without aiding his friend or reporting the incident to authorities, was deemed contrary to human experience. The failure to present Leodegario Petilla or any member of the alleged opposing group to corroborate this story further weakened the defense. In contrast, the prosecution evidence, including the medico-legal findings that the fatal wounds were inflicted from behind, firmly established treachery (alevosia), as the attack was sudden and from behind, denying the victim any chance to defend himself. The Court thus upheld the trial court’s judgment in its entirety.