GR L 72814; (March 1987) (Digest)
G.R. No. L-72814 March 31, 1987
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. GREGORIO NARAJOS, accused-appellant.
FACTS
The accused-appellant, Gregorio Narajos, was convicted of Murder for the killing of Enrico Garzon. The incident stemmed from a prior tumultuous affray between their families, which was reportedly settled with an agreement for payment of medical bills. On September 12, 1976, while the victim, his wife Socorro, and their driver Alejandro Gonzales were conversing at their residence, co-accused Uldarico Prado arrived and confronted Garzon about the hospital expenses. Appellant Narajos suddenly appeared and without warning stabbed Garzon in the chest. A struggle ensued where the knife handle broke from the blade. The wounded victim pulled the blade from his body. As both men fell to the ground, with Narajos trying to retrieve the blade, Prado strangled Garzon. Gonzales intervened, pulling Prado away and boxing him, after which both assailants fled. Garzon died days later from his injuries.
ISSUE
The central issue is whether the trial court erred in its assessment of the evidence and in convicting the appellant, particularly given that the judge who penned the decision did not hear all the witness testimonies directly.
RULING
The Supreme Court affirmed the conviction. On the procedural issue, the Court ruled that a judge may validly decide a case based on the recorded evidence presented before a predecessor judge. This is a settled rule rooted in practicality, especially following judiciary reorganization, and the appellant failed to show any specific prejudice from the judge’s reliance on the transcript of stenographic notes. On the substantive merits, the Court found no reason to overturn the trial court’s credibility findings. The testimonies of eyewitnesses Socorro Garzon and Alejandro Gonzales were clear, consistent, and credible. Their relationship to the victim did not impair their credibility absent proof of improper motive; their natural interest is to see the true culprit convicted. The Court also found that the appellant’s claim of self-defense was untenable, as his sudden, unprovoked attack constituted treachery. The flight of his co-accused did not exculpate him. The decision was affirmed with modification, increasing the civil indemnity to Thirty Thousand Pesos.