GR L 37364 CAstro (Digest)
March 14, 2026GR L 71169; (December, 1988) (Digest)
March 14, 2026G.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 @ “ROMEO CARINGAL”, 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. The prosecution’s case rested primarily on the testimonies of Adelina Villa, an eyewitness, and the victim’s mother, Cristina Eugenio. Villa testified that she saw appellant Romeo Caringal stab the victim while five other persons held him down. Cristina Eugenio testified that her dying son, Francisco, identified Caringal as his assailant while at the hospital. The defense presented alibi, claiming Caringal was elsewhere at the time, and sought to discredit the prosecution witnesses by highlighting inconsistencies and Villa’s initial failure to report the crime to the police out of fear.
ISSUE
The core issue is whether the prosecution proved beyond reasonable doubt that appellant Romeo Caringal is guilty of the murder of Francisco Eugenio.
RULING
The Supreme Court affirmed the conviction for murder but modified the damages awarded. The Court found the testimonies of prosecution witnesses Adelina Villa and Cristina Eugenio credible and sufficient to establish guilt. Villa’s eyewitness account was deemed credible despite her initial fear-induced silence, as the Court recognized that reticence is common among witnesses in violent crimes. The dying declaration testified to by the victim’s mother was also upheld. The Court ruled that the qualifying circumstance of treachery was duly proven because the attack was sudden and employed means that ensured the victim, who was asleep, had no opportunity to defend himself. The defense of alibi was rejected for being weak and unsubstantiated, especially in the face of positive identification. The Court imposed the penalty of reclusion perpetua, in line with constitutional prohibitions, and awarded civil indemnity of P30,000.00, deleting other damages for lack of sufficient evidentiary basis.
