G.R. No. 74657. February 27, 1989.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. LEONARDO SERRANO, accused-appellant.

FACTS

The accused, Leonardo Serrano, was convicted of murder for the killing of Jorge Villapando. The prosecution established that on the night of January 23, 1983, both men were visitors at the house of Lamberto Espeleta, where they conversed with Charito Valencia. Villapando was Valencia’s sweetheart, while Serrano was a suitor. After Villapando decided to leave, Serrano accompanied him. They were escorted by Espeleta to a tricycle driven by Armando Alvarez. While the tricycle was en route to the poblacion, with Villapando seated to Serrano’s left, Serrano stabbed Villapando five times in the chest. Alvarez felt the tricycle sway, looked inside, and saw Serrano still stabbing the victim. Serrano then jumped from the moving vehicle and fled. Villapando was pronounced dead on arrival at the hospital.

ISSUE

The core issue is whether the trial court erred in convicting the accused based on the evidence presented, specifically concerning the credibility of witnesses, the alleged time discrepancy in the incident, the accused’s motive, and the positive identification of the accused as the perpetrator.

RULING

The Supreme Court affirmed the conviction. The Court upheld the trial court’s factual findings, emphasizing the well-settled rule that such findings are accorded great respect and finality unless substantial matters were overlooked. The Court methodically addressed the assigned errors. It found no merit in the claim of a time discrepancy suggesting the victim was already wounded before boarding the tricycle, noting the timeline was not conclusively established and the testimonies of eyewitnesses Alvarez and Espeleta were credible and consistent on the material point: the stabbing occurred inside the tricycle. The Court ruled that motive, while established as jealousy, is not an essential element of the crime where the accused is positively identified. The positive identification by eyewitnesses Alvarez and Espeleta was deemed credible and sufficient. The Court dismissed alleged inconsistencies in the witnesses’ testimonies as minor details pertaining to collateral matters, which in fact bolstered their credibility by showing they were unrehearsed. The Court also rejected the argument that it was incredible for the accused to commit the crime in the presence of a witness, citing contemporary realities where crimes are often committed brazenly. The accused’s flight after the incident further supported guilt. The penalty of reclusion perpetua and the award of damages were thus affirmed.