People v. Romero
REITERATIONFacts
The Antecedents: The accused-appellant, Welmo Romero, along with his brothers Jose and Pludino, were charged with murder for the death of Charlie Relano. The information alleged that the accused, confederating together, with evident premeditation and treachery, attacked and stabbed the victim while he was sleeping, inflicting fatal wounds. Jose Romero was arrested and tried first, but the charge against him was dismissed for insufficiency of evidence. Welmo Romero was apprehended later. The prosecution presented testimonies of the victim's mother-in-law, Filomena Laguerta, and wife, Elena Prasmo, as well as the autopsy report of Dr. Rodolfo Garde. Filomena Laguerta testified that at around 2:00 PM on April 25, 1966, while she was upstairs, Pludino and Welmo Romero entered the house armed with bolos. They proceeded to the room where Charlie Relano and his wife were sleeping. Pludino stabbed Charlie Relano on the left breast, followed by Welmo who stabbed him on the right breast. When Charlie tried to raise his hand, Welmo stabbed his left wrist. Charlie died later that day. The defense presented an alibi, claiming Welmo and his mother were at a clinic with his brother Arturo, who had been stabbed earlier by the victim and his brother. Another defense witness, Florido Relano (victim's brother), testified that only Pludino Romero was present and stabbed Charlie, and Welmo was not there. Procedural History: The Court of First Instance of Masbate found Welmo Romero guilty of murder and sentenced him to reclusion perpetua, to indemnify the heirs, and to pay costs. The accused appealed this judgment. The Petition: The accused-appellant appealed the decision of the trial court.
Issue(s)
Whether the conviction of the appellant for murder is supported by sufficient evidence, particularly the testimony of a single eyewitness. Whether the appellant's flight and subsequent offer to compromise constitute an implied admission of guilt. Whether the defense of alibi, corroborated by the appellant's mother and the victim's brother, sufficiently negates the prosecution's evidence. Whether the aggravating circumstance of dwelling was offset by the mitigating circumstance of provocation, and the admissibility of Dr. Garde's testimony.
Ruling
The Supreme Court affirmed the judgment of the trial court, finding the accused-appellant Welmo Romero guilty of murder. The penalty of reclusion perpetua was upheld, along with the civil indemnity and costs. The Court found that the aggravating circumstance of dwelling was offset by the mitigating circumstance of provocation.
Ratio Decidendi
On the sufficiency of evidence and the testimony of a single eyewitness: The Court held that the positive identification by Filomena Laguerta, a credible eyewitness who knew the appellant, was sufficient to support the conviction for murder. The fact that the crime occurred in daylight, between 2:00 and 3:00 PM, further precluded any possibility of mistaken identity. The Court reiterated the established rule that witnesses are weighed, not numbered, and the testimony of a single witness, if positive and credible, is enough to sustain a conviction, citing People vs. Argana and People vs. Salazar. The trial court's characterization of Filomena's testimony as reliable was given weight due to the court's opportunity to observe the witness's demeanor. On flight and offer of compromise as implied admission of guilt: The Court found that the appellant's flight and prolonged hiding for five years after the warrant of arrest was issued indicated a guilty conscience. Furthermore, the appellant's attempt to compromise the charge by offering money to the victim's relatives, evidenced by a promissory note, was considered an implied admission of guilt, as criminal cases of this nature are not allowed to be settled by compromise, citing Section 24, Rule 123 of the Rules of Court and People vs. Sope. The affidavit of desistance obtained as part of the compromise was deemed part of the deal and not a genuine retraction. On the defense of alibi: The Court found the alibi defense insufficient. It reiterated that for alibi to be credible, the accused must prove not only that he was elsewhere but also that the distance was such as to make it impossible for him to be at the scene of the crime. The Court noted that the distance between the victim's house and the clinic where the appellant claimed to be was not so great as to preclude his presence at the crime scene. The corroborating testimony of the appellant's mother was considered biased due to natural maternal instinct to exculpate her son. The testimony of Florido Relano, the victim's brother, was also doubted due to his six-year delay in reporting his alleged presence at the scene and his lack of interest in the victim's plight, as observed by the trial court. On the aggravating circumstance of dwelling and mitigating circumstance of provocation, and the admissibility of Dr. Garde's testimony: The Court agreed that the crime was qualified by treachery and aggravated by dwelling, as it was committed in the victim's house. However, it found that this aggravating circumstance was offset by the mitigating circumstance of provocation. This provocation arose from the fact that on the morning of the incident, the victim Charlie Relano and his brother Joselito inflicted serious injuries on the appellant's brother, Arturo, which later resulted in Arturo's death. This prior act of aggression by the victim's side provided a basis for appreciating provocation in favor of the appellant. The Court found no necessity to dwell at length on the appellant's argument that Dr. Garde's testimony, given during the trial of his co-accused, was inadmissible due to violation of the right to confrontation. Even if discarded, the nature and location of the injuries and the fact of death were sufficiently established by the testimonies of Filomena Laguerta and Elena Prasmo, who were cross-examined during the appellant's trial. Therefore, the admission of Dr. Garde's testimony did not materially affect the appellant's constitutional rights.
Main Doctrine
The Court affirmed the conviction for murder, holding that the positive identification by a lone credible eyewitness is sufficient for conviction. It also considered the accused's flight and offer of compromise as implied admissions of guilt, while discrediting the alibi defense due to insufficient proof of distance and the biased nature of corroborating witnesses. The aggravating circumstance of dwelling was offset by the mitigating circumstance of provocation arising from the prior stabbing of the accused's brother.