People v. Enriquez
REITERATIONFacts
The Antecedents: Laborers Romeo Enriquez, Manuel Biasa, and Ariel Donato, Jr., engaged in a drinking spree after work. They invited security guard Eduardo Tupig to join them. After consuming several bottles of gin and beer, they proceeded to eat supper. Enriquez borrowed money and they continued drinking at D'Margs Beerhouse. Upon leaving the beerhouse, near a 7-Eleven store, Tupig was stabbed from behind. Tupig was rushed to the hospital but succumbed to the stab wound. Procedural History: Initially, Enriquez, Donato, and Biasa blamed ten unidentified men for Tupig's death. Four months later, Biasa executed sworn statements identifying Enriquez as the stabber and Donato as an accomplice. An information for murder was filed against Enriquez and Donato. At the trial, Biasa affirmed his later statements, testifying that Enriquez had instructed him to bring a knife, which Enriquez used to stab Tupig from behind. Biasa also testified that Donato threatened him to support their agreed narrative. The Medico-Legal Officer concluded Tupig died of hemorrhage secondary to stab wound. Enriquez maintained his defense that ten unidentified men attacked them. The defense witness, SPO1 Armando Cruz, testified he found no witnesses to the alleged attack. The Regional Trial Court of Quezon City, Branch 99, found Romeo Enriquez guilty of murder and sentenced him to reclusion perpetua. The Petition: Enriquez appealed his conviction, asserting the trial court's findings were erroneous and that Biasa's initial statement should have been considered.
Issue(s)
Whether the trial court erred in giving credence to the later sworn statements of Manuel Biasa over his initial statements. Whether the prosecution sufficiently established the guilt of the accused beyond reasonable doubt. Whether the killing was qualified by treachery.
Ruling
The Supreme Court affirmed the decision of the Regional Trial Court, finding accused-appellant Romeo Enriquez guilty beyond reasonable doubt of the crime of murder. The Court sentenced him to suffer the penalty of reclusion perpetua and to pay damages to the heirs of the deceased victim.
Ratio Decidendi
On the credibility of Manuel Biasa's statements: The Court held that in assaying conflicting deeds, the later, more recent act is presumed to be the true will and intent. This presumption is strengthened when the declarant affirms these assertions while testifying under oath. Biasa's later sworn statements, identifying Enriquez as the assailant, were affirmed during trial. The Court reiterated its policy of paying fidelity to the factual findings of the trial court, especially when there is no plausible reason to abandon its conclusions. The Court found Enriquez's version, blaming ten unidentified men, weak due to lack of corroboration and his inability to describe the supposed aggressors. The Court emphasized that positive identification by a credible witness prevails over alibi and denial. On whether the prosecution sufficiently established guilt beyond reasonable doubt: The Court found that Biasa's testimony, which positively identified Enriquez as the stabber, was sufficient. The Court noted that criminals are convicted based on the credibility of testimony, not the number of witnesses. Biasa's testimony was substantiated by the postmortem findings of the Medico-Legal Officer. The Court found no reason to doubt Biasa's credibility, especially since he was identified as Enriquez's protégé and Enriquez had recommended him for employment, suggesting no apparent ill motive for Biasa to falsely accuse Enriquez. On whether the killing was qualified by treachery: The Court agreed with the trial court that the killing was qualified by treachery. Tupig was stabbed from behind, rendering him unable to defend himself due to the suddenness and unexpectedness of the attack. The Court noted that Enriquez's life was never in jeopardy, and his act of bringing the victim to the hospital was seen as a show of feigned concern. The Court defined treachery (alevosia) as an unexpected and sudden attack under circumstances that render the victim unable to defend himself by reason of the suddenness and severity of the attack.
Main Doctrine
Positive identification by a credible witness, even if uncorroborated, prevails over alibi and denial. The later sworn statement of a witness, affirmed on the stand, is presumed to reflect their true intent, especially when the witness vacillated after initial statements.