People v. Alapide
REITERATIONFacts
The Antecedents: Accused-appellant Rolando A. Alapide was charged with murder for allegedly treacherously stabbing Jose Abejo y Subion to death with a bladed weapon. The prosecution presented evidence that the incident occurred around 9:30 P.M. on January 28, 1991, in a mahjong cottage. While the victim, Jose Abejo, was passing in front of the appellant to leave the cottage, the appellant suddenly thrust a bolo ("palas") into the victim's chest. The victim exclaimed that he was hit and ran towards the national road, where he died. The appellant then pointed his weapon at Oscar Monjardin, who parried it, and the appellant stated that the victim had drawn something against him earlier. The appellant fled and was later arrested. The bolo used in the killing was turned over to the authorities. Procedural History: The Regional Trial Court of Virac, Catanduanes, Branch 42, found the appellant guilty of murder beyond reasonable doubt on October 31, 1991. He was sentenced to suffer the penalty of reclusion perpetua and ordered to pay civil indemnity and burial expenses. The Petition: The accused-appellant sought reversal of the trial court's judgment, arguing that the court erred in giving credence to the prosecution's witnesses and in finding him guilty of murder despite the presence of reasonable doubt.
Issue(s)
Whether the accused-appellant acted in self-defense. Whether the killing was attended by treachery, qualifying the crime to murder.
Ruling
The Supreme Court affirmed the decision of the Regional Trial Court, finding the accused-appellant Rolando A. Alapide guilty of murder. The Court sentenced him to suffer the penalty of reclusion perpetua and ordered him to pay civil indemnity and burial expenses to the heirs of the victim.
Ratio Decidendi
On the issue of self-defense: The Court reiterated the rule that when an accused admits the killing and anchors his defense on self-defense, the burden of proof shifts to him to establish this justifying circumstance by clear and convincing evidence. The appellant's version of events, claiming he was hit, dragged outside, and repeatedly pounded on the back by the victim before he swung his bolo, was found to be uncorroborated and lacked credibility. The Court found it improbable that such a commotion, as described by the appellant, could have occurred inside a small cottage with several people present without anyone else noticing it. Defense witnesses Expedito Arcilla and Napoleon Arcilla testified to seeing a commotion and the appellant falling, but neither saw anything that preceded it, nor did they corroborate the appellant's claim of a mauling. The testimony of Oscar Monjardin, who was closest to the scene, positively identified the appellant as the aggressor who suddenly thrust the bolo into the victim's chest. On the presence of treachery: The Court held that the killing was attended by treachery. The prosecution's evidence, particularly the testimony of Oscar Monjardin, established that the appellant suddenly and unexpectedly stabbed the victim on the left chest as the victim was passing in front of him. There was no prior act or conduct by the appellant that could have put the victim on notice of an impending attack. The victim was unarmed and unaware of the impending assault, rendering him unable to defend himself or escape. The Court found that the appellant deliberately adopted a method of attack that insured the accomplishment of his criminal purpose without risk to himself, citing the appellant's strategic seating position near the door, the deliberate carrying of the unsheathed "palas" in his back pocket, and the stealthy speed of the thrust towards a vital part of the victim's anatomy. These circumstances were considered unequivocal indicia of a deliberate plan and intent to inflict a fatal injury with complete absence of resistance from the victim, thus satisfying all the elements of treachery.
Main Doctrine
The Court affirmed the conviction for murder, holding that the elements of treachery were present and that the accused failed to establish the justifying circumstance of self-defense by clear and convincing evidence. The prosecution's evidence, particularly the testimony of Oscar Monjardin, established that the accused suddenly and unexpectedly stabbed the victim without provocation, while the accused's claim of self-defense was uncorroborated and lacked credibility.