GR 93406; (October, 1992) (Digest)
G.R. No. 93406 October 7, 1992
People of the Philippines vs. Roger Arevalo and Edgar Blancaflor
FACTS
Accused-appellants Roger Arevalo and Edgar Blancaflor were charged with the murder of Reynaldo Hernandez. The prosecution established that on the evening of April 3, 1988, during a graduation party at the house of Honorato Navarro in Balud, Masbate, the victim Reynaldo Hernandez was seated upstairs when he was shot in the head by Roger Arevalo, who was standing in the yard holding a gun. Immediately thereafter, Edgar Blancaflor, who had climbed the window beside Hernandez, stabbed him in the neck. The shotgun blast also injured Honorato Navarro. Dr. Jovellano Aguilar, Jr. conducted the autopsy and confirmed that both the shotgun wound to the head and the stab wound to the neck were fatal. Roger Arevalo later surrendered to Police Corporal Harry Estrella and allegedly admitted to the shooting. At trial, Edgar Blancaflor denied being at the scene, claiming alibi. Roger Arevalo admitted to shooting and stabbing Hernandez but claimed self-defense, alleging that Hernandez had first stabbed him twice in the back. The trial court rejected these defenses, found both accused guilty of murder qualified by treachery, and sentenced them accordingly.
ISSUE
Whether the trial court erred in finding accused-appellants Roger Arevalo and Edgar Blancaflor guilty of murder beyond reasonable doubt.
RULING
The Supreme Court affirmed the trial court’s judgment with modification. The Court found the testimonies of the prosecution eyewitnesses, Honorato Navarro and Pasolita Catalan, to be credible, straightforward, and consistent with the medical evidence. The claim of self-defense by Roger Arevalo was rejected as untenable; the nature of the victim’s neck wound would have caused immediate debilitation, making Arevalo’s subsequent narrative of further struggle implausible. His claim of prior stab wounds was unsupported, as the doctor he cited refused to testify, disavowing knowledge of the case. Edgar Blancaflor’s defense of alibi was likewise rejected. The Court upheld the finding of conspiracy and the qualifying circumstance of treachery, as the attack was sudden and rendered the victim defenseless. The indemnity to the victim’s heirs was increased from P30,000.00 to P50,000.00 in accordance with prevailing doctrine. The appealed judgment was affirmed in all other respects.