People v. Alegarbes
REITERATIONFacts
The Antecedents: On June 30, 1984, at approximately 9:00 PM, Nino Velez left his house and joined the accused for a drinking session. Around 11:00 PM, Nino returned home, bleeding from multiple wounds, and died approximately two hours later. The five accused were charged with murder, qualified by treachery and aggravated by nighttime and abuse of superior strength. Only Sedan Alegarbes and Alvin Ucab were apprehended and stood trial. Procedural History: The Regional Trial Court of Cagayan de Oro City convicted Sedan Alegarbes as principal for murder, based mainly on the victim's antemortem statement, and sentenced him to reclusion perpetua. Alvin Ucab was acquitted on reasonable doubt. The decision was appealed to the Supreme Court. The Petition: The appellant contested his conviction, particularly its reliance on the dying declaration, arguing that the victim's condition and the circumstances made it improbable for him to have identified his assailants. He also questioned the award of damages.
Issue(s)
Whether the victim's antemortem statement is admissible and credible as a dying declaration. Whether the appellant's defense of alibi is tenable. Whether the appellant is guilty of murder qualified by treachery. Whether the award of actual and moral damages is justified.
Ruling
The Supreme Court affirmed the decision of the trial court in toto, upholding the conviction of Sedan Alegarbes for murder and the sentence of reclusion perpetua, along with the award of damages.
Ratio Decidendi
On the admissibility and credibility of the dying declaration: The Court held that all requisites for the admissibility of the victim's statements as a dying declaration were present. The statements referred to the cause and circumstances of his death, and he was competent to testify. His declaration was made under the consciousness of imminent death, evidenced by the serious nature of his six stab wounds and his death approximately two hours thereafter. The Court found the victim's ability to communicate and travel to his house medically plausible, further supported by his father's immediate action of calling the police and proceeding to the appellant's house after hearing the victim's identification of his assailants. The appellant's claims of intoxication, darkness, and the victim's condition were unsubstantiated by evidence. The Court noted that the victim had known the accused for a long time, negating any mistaken identity due to confusion. On the defense of alibi: The Court rejected the appellant's defense of alibi, deeming it unavailing due to its inherent weakness and the circumstances of the incident. The appellant's home was near the stabbing location, and his claim of being with his wife who was in labor was not credible, as the child was born fourteen days later. Furthermore, the appellant failed to present evidence to support his alibi, rendering it a mere theoretical surmise. On the guilt of murder qualified by treachery: The Court found sufficient evidence to establish the appellant's guilt for murder. The dying declaration directly implicated the appellant and others. The medical findings indicated that some wounds, particularly those at the back and chest, may have been inflicted simultaneously, making it impossible for a single person to inflict them, thus contradicting the defense's attempt to attribute the crime solely to Richard Agbu, who was at large. The Court also considered the established standing grudge between the victim and the appellant, evidenced by prior incidents where the appellant was seen looking for the victim while armed. On the award of actual and moral damages: The Court found sufficient evidence to justify the award of actual damages, specifically P1,000.00 for hospital expenses and P3,000.00 for funeral parlor expenses, as well as moral damages. The appellant's failure to discuss the reason for his challenge to these damages was noted with displeasure, suggesting it was contingent on his acquittal.
Main Doctrine
The Court affirmed the conviction of the accused for murder, holding that the victim's dying declaration was admissible and credible, despite the appellant's claims of intoxication, darkness, and the victim's condition, and that the defense of alibi was unavailing.