People v. Pajares
REITERATIONFacts
The Antecedents: On March 7, 1988, between 9:00 and 10:00 PM, Alberto Pilapil, an ambulant vegetable vendor, was stabbed from behind on the lower part of his chest while attending to his pushcart at the corner of Bilbao and Padre Rada Streets, Tondo, Manila. The assailant fled towards Bilbao Street. An eyewitness, Reynaldo de Vera, testified that he saw the accused-appellant approach Pilapil from behind, stab him with a bladed instrument about six to seven inches long, and then flee. Pilapil, bleeding profusely, ran towards Ylaya Street to seek medical attention. Police Corporal Amador Regalado, while on patrol, was informed of the incident and, with de Vera, apprehended the accused-appellant fitting the description of the assailant, found to be drunk and holding a pointed weapon. A half-bladed scissor was recovered from the accused-appellant. At the hospital, Pilapil, who was still alive and conscious, identified the accused-appellant as his assailant. The accused-appellant, represented by counsel, verbally admitted to the stabbing during custodial investigation, though not reduced to writing. Pilapil died the following night, March 8, 1988, at 10:35 PM. Procedural History: The Regional Trial Court of Manila, Special Criminal Court, Branch 5, found the accused-appellant Sulpicio Pajares y Hagonoy guilty of murder and sentenced him to life imprisonment, to indemnify the heirs of the deceased P30,000.00, and to pay costs. The Petition: The accused-appellant appealed the decision, arguing that treachery, evident premeditation, and other elements of murder were not proven, that no motive was shown, that the victim's identification was not formalized in writing, and that the penalty was excessive.
Issue(s)
Whether treachery, evident premeditation, and other elements of murder were proven beyond reasonable doubt. Whether the absence of a shown motive creates doubt as to the accused-appellant's participation. Whether the victim's oral identification of the accused-appellant, not formalized in writing, is admissible and sufficient for conviction. Whether the penalty imposed is excessive and disproportionate.
Ruling
The Supreme Court affirmed the judgment of the lower court with modifications. The penalty was corrected to reclusion perpetua, and the indemnity was increased to P50,000.00.
Ratio Decidendi
On the elements of murder and treachery: The Court found that treachery was clearly established by the eyewitness testimony of Reynaldo de Vera. The accused-appellant suddenly and unexpectedly attacked the victim from behind, without provocation, thereby insuring the commission of the crime without risk to himself. The Court reiterated the rule that treachery exists when the offender adopts means or methods that insure the commission of the felony without risk to himself arising from any defense the offended party might take. The sudden and unexpected stabbing from behind, as testified to by the eyewitness, squarely fits this definition. While evident premeditation was not proven, treachery alone is sufficient to qualify the killing to murder. On the issue of motive: The Court held that proof of motive is not indispensable for conviction, especially when the identity of the culprit is not in doubt. The prosecution presented solid evidence establishing the identity of the accused-appellant as the perpetrator. The absence of a proven motive does not create reasonable doubt when other evidence conclusively points to the accused-appellant's guilt. The focus is on whether the crime was committed and if the accused committed it, not necessarily why he committed it, if other evidence is strong. On the admissibility and sufficiency of the victim's identification: The Court found the victim's identification of the accused-appellant to be sufficient. Although the identification was not reduced to writing, it was made by the victim while alive and conscious, in the presence of a police officer and the accused-appellant's counsel. This direct confrontation and identification, coupled with the positive identification by the eyewitness and the police, provided strong evidence of guilt. The Court noted that the accused-appellant's verbal admission during custodial investigation, though unwritten, was made in the presence of counsel, lending it credibility. On the penalty and indemnity: The Court affirmed the conviction for murder. Applying Article 248 of the Revised Penal Code, the penalty for murder is reclusion perpetua. The Court also increased the indemnity to P50,000.00, conforming to prevailing jurisprudence at the time. The Court found the accused-appellant's defense of bare denial to be weak and insufficient to overcome the strong evidence presented by the prosecution, which included the eyewitness testimony, the victim's dying identification, and the positive identification by the eyewitness at the police headquarters.
Main Doctrine
Treachery was clearly established by the eyewitness testimony, negating the defense of denial. Proof of motive is not indispensable for conviction when the identity of the culprit is established. The penalty for murder is reclusion perpetua, and the indemnity for death is P50,000.00.