People v. Aliposa
REITERATIONFacts
The Antecedents: On August 20, 1990, during a town fiesta in Catarman, Northern Samar, Sonny Tonog was stabbed and killed. The prosecution alleged that Joel Aliposa and Crispin Velarde, armed with a bolo and a fan knife respectively, conspired to kill Sonny Tonog with treachery and evident premeditation. Eyewitnesses Enrique Saludario and Pedro Jumadiao testified that Aliposa embraced Sonny Tonog, pulled him aside, and stabbed him twice, after which Velarde also stabbed the victim. The assailants then fled and were pursued by Lt. Isaias Tonog, the victim's cousin and Police Station Commander, who apprehended them at Crispin Velarde's house. The victim sustained multiple stab wounds, with the cause of death being cardiopulmonary arrest and massive hemorrhage. Procedural History: The Regional Trial Court of Catarman (Branch 19) found Joel Aliposa and Crispin Velarde guilty beyond reasonable doubt of murder and sentenced them to reclusion perpetua. They were ordered to indemnify the heirs of Sonny Tonog and pay funeral expenses. The Petition: Only Crispin Velarde appealed his conviction, assigning errors to the trial court for relying on contradictory testimonies and disregarding Aliposa's admission of sole culpability.
Issue(s)
Whether the trial court erred in convicting Crispin Velarde based on the testimonies of prosecution witnesses. Whether Aliposa's admission that he alone stabbed the victim should have been given weight to exculpate Velarde, and whether Velarde's alibi was credible. Whether treachery was sufficiently established as a qualifying circumstance for murder.
Ruling
The Supreme Court affirmed the decision of the trial court, finding Crispin Velarde guilty of murder. The Court increased the indemnity to be paid to the heirs of Sonny Tonog to P50,000.00.
Ratio Decidendi
On the conviction of Crispin Velarde based on prosecution witnesses: The Court found the testimonies of eyewitnesses Saludario and Jumadiao to be lucid, unshaken by cross-examination, and consistent on all material points. These points included the approach of the assailants, Aliposa's action of encircling Sonny's shoulders, Velarde's positioning on the victim's other side, the stabbing actions of both Aliposa and Velarde, Sonny falling on his back, and the subsequent chase. The medico-legal findings corroborated the eyewitness accounts regarding the nature and location of the wounds, supporting the possibility of multiple assailants and the trajectory of wound No. 3 indicating an assailant from the victim's left side. The Court also found no bias in Lt. Tonog's testimony despite his relationship to the victim, noting that the accused were also relatives and there was no proof of improper motive. On Aliposa's admission and Velarde's alibi: The Court rejected Aliposa's claim of self-defense and his assertion that he acted alone. Aliposa's defense was found to be inconsistent and inherently incredible. Velarde's alibi, that he was at home watching a Betamax tape when the killing occurred, was also rejected. It lacked credible corroboration, as the defense witnesses could not pinpoint the exact time of Velarde's arrival home. Furthermore, the alibi did not demonstrate the physical impossibility of Velarde's presence at the crime scene. The positive identification by eyewitnesses, who had no motive to testify falsely, outweighed the uncorroborated alibi. On the qualifying circumstance of treachery (alevosia): The Court found that treachery was sufficiently established. The manner of attack, with Aliposa encircling the victim's shoulders and delivering blows while Velarde positioned himself on the victim's left side and also inflicted a stab wound, demonstrated a deliberate plan to ensure the execution of the crime without risk to the assailants. This method of attack directly and specially insured the execution of the crime, preventing any defense the victim might have made. The coordinated attack signified unity of purpose and intention. Although evident premeditation was not clearly established, the circumstance of treachery qualified the crime to murder.
Main Doctrine
The Court affirmed the conviction for murder, holding that the prosecution sufficiently established treachery as a qualifying circumstance, and rejected the defense of self-defense and alibi due to lack of credible corroboration and inconsistencies. The testimonies of eyewitnesses were found to be consistent and credible, corroborating each other on material points.