People v. De Leon
REITERATIONFacts
The Antecedents: On November 14, 1988, around 8:00 p.m., Cesar Cruz was watching television near the pier. Two persons, identified as Celedonio de Leon and Ruben Alarcon, approached Cruz from behind. De Leon stabbed Cruz in the left upper back while Alarcon held Cruz's other hand. Despite the injury, Cruz ran towards his motor launch, M/V Arayat. Edmar Ramirez, a co-worker, witnessed the stabbing and identified De Leon as the stabber and Alarcon as the one holding Cruz's hand. Dinia Dala Saludes, daughter of the owner of M/V Arayat, also witnessed the incident and heard Alarcon shout a threat towards the crew of M/V Arayat. A police sergeant, accompanied by Saludes, apprehended De Leon and Alarcon on board M/V Gerlyn II. Cesar Cruz died that same night due to hemorrhage caused by the stab wound. Ramirez executed an affidavit identifying De Leon and Alarcon. An information for murder was filed against them. Procedural History: The Regional Trial Court (RTC) of Lucena City, Branch 58, convicted both accused of murder, sentencing them to reclusion perpetua and ordering them to pay civil indemnity. The trial court found conspiracy and the qualifying circumstance of treachery to be duly established. The Petition: The accused appealed the RTC decision, assigning errors concerning the credibility of witnesses Edmar Ramirez and Dinia Dala Saludes, the finding of conspiracy and treachery, and their conviction.
Issue(s)
Whether the trial court erred in believing the testimony of Edmar Ramirez, considering his subsequent affidavit of recantation and repudiation. Whether the trial court erred in giving credence to the corroborating testimony of Dinia Dala Saludes. Whether the trial court erred in finding conspiracy and/or confederacy between the appellants and treachery in the stabbing of Cesar Cruz. Whether the trial court erred in convicting the appellants of murder.
Ruling
The Supreme Court affirmed the decision of the Regional Trial Court, finding no reversible error. The appeal was dismissed, and the conviction of Celedonio de Leon and Ruben Alarcon for murder was affirmed in toto.
Ratio Decidendi
On the credibility of Edmar Ramirez: The Court found that Ramirez's initial affidavit, executed on the night of the incident, was credible and later confirmed by his subsequent affidavit repudiating his recantation. The recantation was explained by the threat from the appellants' employer and the monetary consideration, making it unreliable. Ramirez's age (seventeen at the time) made him vulnerable to such threats. His subsequent reaffirmation of his original statement, coupled with corroboration from another witness, entitled his testimony to full faith and credit. The Court reiterated that affidavits of recantation are generally considered exceedingly unreliable. On the credibility of Dinia Dala Saludes: The Court found Saludes's testimony credible. Her failure to execute an affidavit immediately did not diminish her credibility, as she was instrumental in the arrest of the appellants and actively participated in their pursuit. The defense failed to show any improper motive for her testimony, and it was noted that Alarcon was her kumpadre, suggesting a potential reason for her to be truthful rather than fabricating a story. The Court emphasized that the trial court's assessment of witness credibility is entitled to great weight. On conspiracy and treachery: The Court found that conspiracy could be inferred from the appellants' joint actions before, during, and after the crime. These actions included coming to the scene together, Alarcon holding the victim's hand while De Leon stabbed him, Alarcon's threatening statement, and their joint departure on the vessel, which sailed prematurely. The Court held that the act of one conspirator is the act of all. Regarding treachery, the Court found that the appellants approached the victim from behind, attacked him suddenly and unexpectedly, and held him, depriving him of the ability to defend himself. The fatal wound inflicted at the back further supported the presence of treachery, qualifying the crime to murder. On the conviction for murder: Based on the established conspiracy and the presence of treachery, the Court affirmed the conviction for murder. The appellants' contention of incomplete self-defense was dismissed, as De Leon's claim of unintentional stabbing was made only during investigation and was not raised immediately. The premature departure of the vessel was considered indicative of flight, negating the claim of self-defense. The Court concluded that the killing was sudden, unexpected, and from behind, with the victim's hands restrained, thus fulfilling the elements of treachery.
Main Doctrine
Conspiracy may be inferred from the acts of the appellants before, during, and after the commission of the crime which are indicative of a joint purpose, concerted action, and concurrence of sentiments. The premature departure of the vessel where the appellants sought refuge is indicative of flight, thus negating the theory of self-defense. The evidence for the prosecution showing that the appellants approached the victim from behind and attacked him suddenly, unexpectedly, and without any warning, coupled with the victim being held tightly by both appellants, depriving his hands of freedom of movement, and the solitary fatal wound inflicted at the back of the victim's body, establish the existence of treachery.