People v. Escoltero
REITERATIONFacts
The Antecedents: On August 19, 1981, in Iloilo City, Ambrosio Hosillos and his companions were walking home when they were waylaid by Rodrigo Escoltero and Rodolfo Once. The accused allegedly blocked their path, pushed Hosillos against a concrete wall, and then took turns stabbing him with a knife and a sharp pointed instrument, inflicting multiple fatal wounds. The accused fled the scene. Hosillos was brought to the hospital but died instantaneously. The companions of the victim identified Escoltero and Once to the police. Procedural History: Rodrigo Escoltero was charged with murder. He pleaded not guilty. Rodolfo Once remained at large. The trial court found Escoltero guilty of murder, qualified by treachery, and sentenced him to reclusion perpetua, with an indemnity of P12,000.00. The Petition: Appellant Escoltero appealed the decision, arguing that the crime committed was homicide, not murder, and that the trial court erred in giving credence to the prosecution witnesses despite alleged inconsistencies in their testimonies. He also questioned the finding that his presence was unrebutted.
Issue(s)
Whether the trial court erred in holding the accused-appellant guilty of murder, qualified by treachery. Whether the offense committed was homicide and not murder, even if the accused-appellant participated in the stabbing. Whether the trial court erred in considering the testimonies of the prosecution witnesses as overwhelming proof despite alleged inconsistencies. Whether the trial court erred in holding that the presence of the two prosecution witnesses at the scene of the crime remained undenied by the accused-appellant, and on the appellant's flight and evasion of arrest.
Ruling
The Supreme Court affirmed the judgment of the trial court with modification, increasing the indemnity to P30,000.00. The Court found Rodrigo Escoltero guilty of murder, qualified by treachery, and sentenced him to reclusion perpetua.
Ratio Decidendi
On the issue of murder qualified by treachery: The Court held that treachery was present. The victim, Ambrosio Hosillos, was unarmed and was suddenly confronted by the accused who were armed. They pushed the victim against a concrete wall, rendering him helpless, and then took turns stabbing him without warning. This mode of attack ensured the commission of the crime without risk to the assailants and deprived the victim of any opportunity to defend himself, thus qualifying the crime as murder under Article 14, paragraph 16 of the Revised Penal Code. The multiple stab wounds inflicted further supported the prosecution's version. On the issue of homicide versus murder: The Court reiterated that treachery is a qualifying circumstance that elevates homicide to murder. The manner of the attack, as described by the prosecution witnesses and corroborated by the autopsy findings of multiple stab wounds, clearly demonstrated the presence of treachery. The appellant's claim that the incident arose from a fistfight was rejected by the trial court, which gave credence to the prosecution's account of a planned ambush. On the alleged inconsistencies in prosecution witnesses' testimonies: The Court found that the alleged inconsistencies pertained to minor details, such as distances and the exact movements of the parties, which did not affect the integrity of their testimonies. The Court emphasized that perfect uniformity in testimonies is not expected and may even indicate rehearsed statements. The trial court, having observed the witnesses' demeanor, found them credible, and their positive identification of the appellant, coupled with their prior acquaintance with him, was given full faith and credit. The Court cited People v. Paculba and People v. Alcantara in support of this principle. On the denial of the presence of prosecution witnesses and the appellant's flight and evasion of arrest: The Court found the appellant's contention regarding the denial of the presence of prosecution witnesses to be without merit. While the appellant initially claimed not to know Hosillos' companions, he later expressed uncertainty when cross-examined about whether Custodio and Gedalanga were present. This lack of clear denial, combined with the positive identification by Custodio and Gedalanga, who were established as companions of the victim, supported the prosecution's case. The appellant's own testimony, when taken with other evidence, did not effectively rebut their presence. The Court also noted that the appellant disappeared from his residence after a warrant for his arrest was issued and was only apprehended over a year later. This prolonged evasion of arrest, without any justifying explanation, was considered by the Court as incompatible with his claim of innocence and as a strong indication of guilt, citing People v. Pospos.
Main Doctrine
The presence of treachery is established when the attack is sudden and unexpected, giving the victim no opportunity to defend himself, and the means employed are such as to insure the commission of the crime without risk to the assailants. Flight and evasion of arrest are strong indications of guilt.