People v. Rellon
REITERATIONFacts
The Antecedents: Appellant Eugenio Rellon alias "Genio" was charged with Murder for allegedly stabbing Arsenio Ram on January 16, 1983, at around 5:30 PM in Cebu City. The Information alleged that the accused, armed with a deadly weapon, with treachery and evident premeditation, deliberately and with intent to kill, suddenly and unexpectedly stabbed Arsenio Ram on the neck and at the back, inflicting severe hemorrhage secondary to multiple incised hack stab wounds, causing instantaneous death. Procedural History: The trial court found the accused guilty of murder beyond reasonable doubt, sentencing him to reclusion perpetua, to indemnify the heirs of the deceased in the amount of P30,000.00, and to pay the costs. The Petition: The accused appealed the decision, assigning as the sole error the conviction for murder instead of homicide.
Issue(s)
Whether or not the lower court erred in convicting the accused for Murder instead of Homicide by properly appreciating treachery.
Ruling
The Supreme Court affirmed the decision of the trial court, finding the accused guilty of murder. The sentence was modified to an indeterminate term of ten (10) years and one (1) day of prision mayor as minimum to eighteen (18) years, eight (8) months and one (1) day of reclusion temporal as maximum, considering the Indeterminate Sentence Law. Costs were assessed against the appellant.
Ratio Decidendi
On Issue 1: The Court found no error in the lower court's conviction of the accused for Murder, specifically in its appreciation of treachery. The evidence presented by the prosecution, particularly the testimony of Virginia Lusareto, the lone eyewitness, unequivocally established that the appellant stabbed Arsenio Ram at the back with a butcher's knife. The trial court correctly held that the crime committed was murder due to the presence of treachery, noting that the victim was suddenly stabbed from behind while he was engrossed in watching the Sinulog festival. Treachery is defined in Paragraph 16, Article 14 of the Revised Penal Code as existing "when the offender commits any of the crimes against the person, employing means, methods or forms in the execution thereof which tend directly and specially to insure its execution, without risk to himself arising from the defense which the offended party might make." The Court reiterated that two conditions constitute treachery: (1) employment of means of execution so as to give the person attacked no opportunity to defend himself or retaliate; and (2) that such means of execution was deliberately or consciously adopted, citing People v. Samonte, Jr. (64 SCRA 319). In this case, the victim was sitting on a bench, unaware and unprepared, when the appellant stealthily stabbed him from behind, which jurisprudentially constitutes a sudden and unexpected attack without warning, characteristic of alevosia. The appellant's claim of self-defense was effectively rebutted by the prosecution's credible eyewitness account of a deliberate, sudden, and unprovoked attack.
Main Doctrine
The Supreme Court affirmed the conviction for murder, holding that treachery was present when the victim was suddenly and unexpectedly stabbed from behind while engrossed in watching a festival, affording him no opportunity to defend himself. The Court also modified the sentence to an indeterminate term considering the Indeterminate Sentence Law.