G.R. No. 75368 August 11, 1989
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ROMEO CARINGAL y EUGENIO @ “ROMEO CARINGAL”, et al., defendants, ROMEO CARINGAL y EUGENIO, defendant-appellant.

FACTS

In the early morning of January 4, 1983, Francisco Eugenio was stabbed to death while asleep inside a market stall in the Galas public market, Quezon City. He was initially taken to a hospital but later transferred to the Jose Reyes Memorial Hospital where he died from massive hemorrhage due to a stab wound. Based on sworn statements from the victim’s mother, Cristina, and brother, Michael, given later that day, five suspects were identified. The statements alleged that Francisco, before his death, named appellant Romeo Caringal as the person who stabbed him and four others as companions who held him down. An Information for Murder was filed against all five. Only Caringal and co-accused Reynaldo Macuping were apprehended and tried.
At trial, the prosecution presented Adelina Villa, who testified she witnessed the stabbing from about ten meters away, seeing Caringal stab the victim while others held him. She fled and informed the victim’s mother but did not initially report to the police out of fear. Cristina Eugenio corroborated her son’s ante-mortem identification of his assailants. The defense presented alibi, claiming Caringal was elsewhere, and sought to discredit the eyewitness, arguing her testimony was unreliable due to alleged inconsistencies and her failure to report promptly.

ISSUE

The core issue is whether the prosecution proved beyond reasonable doubt that appellant Romeo Caringal is guilty of the crime of Murder.

RULING

The Supreme Court affirmed the conviction. The Court found the testimony of eyewitness Adelina Villa to be credible and sufficient to establish guilt. Her positive identification of Caringal as the perpetrator, provided in a clear and straightforward manner, prevailed over the appellant’s denial and alibi. The Court held that alibi is inherently weak and cannot stand against positive identification by a credible witness. The delay in Villa’s formal reporting to the police was satisfactorily explained by her genuine fear of retaliation from the assailants, which does not impair her credibility.
The Court also upheld the trial court’s finding of treachery (alevosia). The attack was executed in a manner that ensured the victim, who was asleep and defenseless, had no opportunity to resist or defend himself. The sudden and unexpected nature of the assault qualified the killing as Murder. However, the Court modified the damages awarded, deleting the separate awards for moral and compensatory damages and loss of earning capacity. It sustained the civil indemnity of P30,000.00 for the death of Francisco Eugenio. The penalty of reclusion perpetua was affirmed, being the proper penalty for Murder absent any aggravating or mitigating circumstances.