G.R. No. 90766, August 13, 1990
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. FELIX RAQUIPO y TOLENTINO, accused-appellant.

FACTS

Accused-appellant Felix Raquipo was charged with murder for the stabbing death of Estifanio Permejo on January 10, 1985, at the Technological Institute of the Philippines. The prosecution’s case rested primarily on the testimony of security guard Elieser Odevillas. Odevillas testified that earlier on the day of the killing, he saw Raquipo and two companions creating a disturbance on the school’s second floor and ordered them to leave. Later, at around 6:00 p.m., Odevillas saw Raquipo and the same two companions rushing out of a men’s comfort room, with Raquipo wiping his bloodied hands with a handkerchief. Upon entering the comfort room, Odevillas discovered the lifeless body of Permejo sprawled in a pool of blood. The medico-legal report confirmed the victim died from multiple stab wounds.
The defense presented Raquipo as its lone witness, who denied involvement and claimed he went home after his classes. He alleged he was framed by other students whose fraternity invitation he had declined. However, he failed to present these alleged culprits as witnesses. The trial court convicted Raquipo of murder qualified by treachery and evident premeditation, sentencing him to reclusion perpetua and ordering him to pay substantial damages.

ISSUE

Whether the trial court erred in convicting appellant of murder based on circumstantial evidence and in appreciating the qualifying circumstances of treachery and evident premeditation.

RULING

The Supreme Court affirmed the conviction but modified the crime and penalty. The Court held that while no eyewitness saw the actual stabbing, the conviction based on circumstantial evidence was proper. The requisites for circumstantial evidence were satisfied: there was more than one circumstance; the facts were proven; and their combination produced a conviction beyond reasonable doubt. The circumstances—Raquipo creating trouble earlier, being seen fleeing the crime scene with bloodied hands immediately before the body was discovered, and the lack of motive for the guard to fabricate testimony—were consistent with guilt and inconsistent with innocence.
However, the Court ruled that the qualifying circumstances of treachery and evident premeditation were not proven. The prosecution failed to establish how the attack commenced, which is necessary to prove treachery. Evident premeditation requires proof of planning and reflection, which was also absent. Consequently, the crime is homicide, not murder. Applying the Indeterminate Sentence Law, the penalty was reduced to an indeterminate sentence of eight years and one day of prision mayor as minimum, to fourteen years, eight months and one day of reclusion temporal as maximum. Civil indemnity was adjusted to P30,000.00, with actual damages reduced to the proven amount of P39,600.00, and the award for attorney’s fees was deleted.