People v. Raquel
REITERATIONFacts
The Antecedents: Francisco Dador and his wife, Julita Arboso, attended a fiesta in barrio Tinambacan, Jaro, Leyte. While Francisco Dador was taking supper with twelve other guests in a house, a gunshot was heard, and Francisco Dador exclaimed in pain and fell from his seat. Julita Arboso, upon seeing her husband shot, immediately took a flashlight to seek help from the police. As she was going out of the door, she saw the accused, Santiago Raquel, aiming a gun at her and heard him say, "Your husband will not live again." She then told her husband that Santiago Raquel shot him, to which Francisco Dador replied, "Yes, I know, formerly he promised that he will kill me if I would testify as government witness in the case against them because they were accused in that case of the killing of Tuazon." Policemen arrived, questioned Francisco Dador and Julita Arboso, and took a signed statement from Francisco Dador. Francisco Dador was admitted to the hospital for a gunshot wound, where he underwent surgery to remove a slug. He was discharged on July 2, 1959, and died the following day, July 3, 1959. The attending physician testified that the wound was fatal. Procedural History: The accused, Santiago Raquel, was prosecuted for murder before the Court of First Instance of Leyte. The accused interposed the defense of alibi. The trial court found for the prosecution, convicted the accused of murder, and sentenced him to reclusion perpetua, with accessories, ordered him to indemnify the heirs of the deceased, and to pay costs. The Petition: The accused appealed the decision, assigning as the sole error the court's reliance on the testimony of the deceased's wife and the deceased's statement regarding the motive, arguing that the wife's actions were incredible and that the motive was not properly considered.
Issue(s)
Whether the testimony of the deceased's wife, Julita Arboso, is credible despite her actions being characterized as unusual. Whether the deceased's statement regarding the accused's motive is admissible and relevant. Whether the defense of alibi was correctly rejected. Whether the offense committed is murder, qualified by treachery.
Ruling
The Supreme Court affirmed the decision of the trial court with a modification regarding the indemnity, holding that the offense committed is murder qualified by treachery. The Court found the testimony of Julita Arboso to be credible, rejected the defense of alibi, and upheld the conviction of the accused.
Ratio Decidendi
On the credibility of Julita Arboso's testimony: The Court found Julita Arboso's testimony to be credible, rejecting the appellant's argument that her actions were unusual. The Court stated that different persons respond to crises differently and that the impulse to call the police is natural. It highlighted Julita Arboso's courage, presence of mind, and practical judgment, noting her responses during cross-examination and her actions in attending to her infant and later taking her husband from the hospital, demonstrating her independent judgment. The Court also refuted the notion that her seeing the accused near the door was a deliberate disclosure of identity, stating that his position near the door concealed him and she saw him only because she defied danger to seek help. The Court emphasized that what is not ordinary is not necessarily incredible and cited historical examples of women's valor. On the deceased's statement regarding motive: The Court held that the deceased's statement regarding the accused's motive for killing him was not important because the accused was clearly and positively identified as the perpetrator by Julita Arboso, whose testimony was found to be credible. The Court noted that Julita Arboso named the accused spontaneously and without hesitation, first to her husband and then to the police. It also mentioned that the appellant admitted the lack of motive on the part of Julita Arboso to falsely impute the crime against him, citing several cases in support. On the rejection of the defense of alibi: The Court correctly rejected the defense of alibi. It noted that the accused was clearly and positively identified by a credible witness. Furthermore, the distance between the poblacion of Jaro and barrio Tinambacan was only about four and a half kilometers, making it physically possible for the accused to be at the scene of the crime. The Court also found the testimony of the accused's witnesses regarding the time of his departure from Catalina Zabala-Lopez's house unconvincing due to the exact and uniform time given without special reason and their close association with the accused. On the qualification of the offense to murder: The Court ruled that the act was attended with treachery, qualifying the offense to murder. This was based on the fact that the appellant shot the victim from behind during nighttime while the latter was taking his supper. The Court found no mitigating or aggravating circumstances, thus affirming the imposition of reclusion perpetua under Article 248 of the Revised Penal Code.
Main Doctrine
The presence of treachery qualifies the offense to murder when the victim is shot from behind during nighttime while taking supper. The defense of alibi is correctly rejected when the accused is clearly and positively identified and there is no physical impossibility for him to be at the scene of the crime. The testimony of a witness, especially the victim's wife, regarding the identity of the assailant and the motive, is credible if she spontaneously identified the accused and there is no apparent motive for her to falsely impute the crime.