G.R. No. L-77968 November 23, 1988
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. DEMETRIO MARAVILLA, JR., accused-appellant.

FACTS

The accused-appellant, Demetrio Maravilla, Jr., was charged with the murder of Herminio Matutina in Zarraga, Iloilo, on July 5, 1981. The information alleged that the accused, armed with a butcher’s knife, attacked the victim with treachery and evident premeditation, taking advantage of nighttime. The prosecution’s case primarily rested on the eyewitness account of Mario Malba, who testified that he was walking home with the intoxicated victim, supporting him, when the victim suddenly shouted he had been stabbed. Malba looked back and saw the accused about two steps behind, poised to stab him as well, but the accused fled when Malba shouted for help. Malba positively identified the accused, whom he had known since childhood, stating the moon provided illumination. This account was corroborated by witness Ricardo Bendol, who saw the assailant approach from behind and flee after the stabbing. The autopsy confirmed the victim died from a stab wound on the right side of his back, inflicted by a pointed, single-bladed instrument.
The defense presented an alibi, with witness Aida Latumbo testifying that the accused was working as her houseboy in a different municipality on the day of the incident and seldom visited his hometown. The defense also questioned the credibility of Malba’s identification due to the nighttime setting. The trial court convicted the accused of murder, sentenced him to reclusion perpetua, and ordered him to pay indemnity and burial expenses. The accused appealed, arguing the trial court erred in relying on Malba’s testimony, interpreting his flight as guilt, and rejecting the defense’s alibi.

ISSUE

The fundamental issue is whether the guilt of the accused for the crime of murder was proven beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction but modified the penalty and awards. The Court found the prosecution’s evidence sufficient to establish guilt beyond reasonable doubt. The positive identification by eyewitness Mario Malba, who had known the accused since childhood and recognized him under moonlight, was deemed credible and prevailed over the accused’s alibi. The Court upheld the trial court’s assessment of witness credibility, noting no ill motive was shown for Malba to falsely testify. The accused’s flight after the incident, evidenced by his failure to reside at his known address until arrested years later, was properly considered as indicative of guilt.
The qualifying circumstance of treachery was correctly appreciated. The attack from behind on an intoxicated victim who was being assisted while walking rendered him defenseless and unable to retaliate, ensuring the execution of the criminal act without risk to the assailant. Nighttime was not separately considered as it was absorbed by treachery. However, evident premeditation was not established due to lack of proof of sufficient reflection and persistence in the criminal intent.
Regarding the penalty, with the abolition of the death penalty and no aggravating or mitigating circumstances, the proper penalty is reclusion temporal maximum to reclusion perpetua. Applying the Indeterminate Sentence Law, the Court imposed an indeterminate penalty of twelve years and one day of reclusion temporal as minimum, to twenty years of reclusion temporal as maximum. The Court increased the civil indemnity to P30,000.00 but set aside the unsubstantiated award of P5,000.00 for burial expenses due to lack of receipts.