G.R. No. L-37748, September 2, 1983
The People of the Philippines, Plaintiff-Appellee, v. Guerrero Almeda alias “Arte”, Defendant-Appellant.

FACTS

On October 5, 1969, Florentino Navalta was waiting for food inside the restaurant of appellant Guerrero Almeda. He was resting on a bench with his hat over his face when Almeda arrived. Without warning, Almeda delivered fist blows to Navalta’s stomach, then grabbed a piece of wood and repeatedly struck the same area. An eyewitness, Victoriano Taroma, attempted to intervene but was threatened. Navalta was taken home, where he identified Almeda as his assailant to his son-in-law. Two days later, due to severe pain, Navalta was hospitalized.
At the hospital, in a very weak and serious condition, Navalta gave an ante-mortem statement to a PC soldier, explicitly naming “Arte Almeda” as the person who mauled him. This statement was witnessed by a doctor. Approximately thirty minutes after giving this declaration, Navalta died. An autopsy revealed his death was caused by massive internal injuries consistent with blunt force trauma to the abdomen.

ISSUE

The primary issues were: (1) the admissibility of Navalta’s ante-mortem statement as a dying declaration; (2) the sufficiency of the prosecution’s evidence to establish guilt beyond reasonable doubt; and (3) the proper appreciation of treachery as a qualifying circumstance.

RULING

The Supreme Court affirmed the conviction. The Court held that Navalta’s statement was a valid dying declaration admissible as an exception to the hearsay rule. All requisites were present: it concerned the cause and circumstances of his death; it was made under a consciousness of impending death, evidenced by his grave condition and utterance “I will die with this”; he was competent; and it was offered in a murder case where he was the victim. This declaration was corroborated by the credible eyewitness account of Victoriano Taroma, who positively identified Almeda and detailed the unprovoked attack. Minor inconsistencies in Taroma’s testimony did not impair his overall credibility.
The Court further ruled that treachery (alevosia) was correctly appreciated to qualify the killing to murder. The attack was sudden and deliberate, executed while the victim was resting in a defenseless position, ensuring the execution without risk to the assailant. The defense of alibi was rejected for being weak and uncorroborated, and it could not prevail over the positive identification by the prosecution witnesses. The Court also noted the lack of police blotter entry was plausibly due to the influence of the municipal mayor, who was the appellant’s uncle, underscoring the strength of the evidence for the prosecution. The judgment of the trial court was affirmed in toto.