People v. Atrejenio
REITERATIONFacts
The Antecedents: On July 27, 1986, at approximately 8:00 p.m., Bonifacio Olino y Jose was shot while walking along Osmeña Street, Tondo, Manila. The assailant, identified as Rodolfo Atrejenio y Libanan, allegedly emerged from behind a culvert and fired a .38 caliber revolver at the victim, hitting him on the left chest. The victim was rushed to Mary Johnston Hospital but was declared dead on arrival. The victim, before succumbing, identified the accused-appellant as his assailant to his cousin, Lito J. Olino. Procedural History: The accused-appellant, Rodolfo Atrejenio y Libanan, was charged with murder. He pleaded not guilty. The prosecution presented eyewitnesses Lito J. Olino and Leonito Toltol, along with Dr. Marcial G. Cenido (medico-legal officer), Patrolman Salvador C. Fradejas (investigator), and Ernie R. Magtibay (ballistician). The defense presented the accused-appellant and his friends, Eduardo Viojan and Alfredo Ramirez, who claimed the accused-appellant was with them at the time of the shooting. The Regional Trial Court of Manila, Branch 12, found the accused-appellant guilty beyond reasonable doubt of murder and sentenced him to reclusion perpetua and to indemnify the heirs of the victim in the amount of P50,000.00. The Petition: The accused-appellant appealed the decision, contending that the trial court should have acquitted him on the ground of reasonable doubt.
Issue(s)
Whether the guilt of the accused-appellant was proven beyond reasonable doubt, and the credibility of prosecution witnesses. Whether the confession made to Pfc. Fradejas was admissible in evidence. Whether the accused-appellant's alibi was sufficient to overcome the prosecution's evidence. Whether the killing was qualified by treachery. Whether the trial court erred in its award of damages.
Ruling
The Supreme Court affirmed the decision of the Regional Trial Court, finding the accused-appellant guilty beyond reasonable doubt of murder. The Court modified the award of damages, ordering the accused-appellant to pay the heirs of the victim an additional P50,000.00 as moral damages.
Ratio Decidendi
On the issue of reasonable doubt and the credibility of witnesses: The Court held that the trial court's findings on the credibility of witnesses are entitled to great weight. The dying declaration of the victim, identifying the accused-appellant as his assailant, was considered a strong basis for conviction because it met the requisites for admissibility as an ante mortem statement. The eyewitness testimonies corroborated the dying declaration and the circumstances of the shooting. Affidavits are generally inferior to testimony given in open court. On the admissibility of the confession: The Court agreed with the trial court in disregarding the testimony of Pfc. Fradejas regarding the accused-appellant's oral admission of guilt because the confession was obtained in violation of the accused-appellant's Miranda rights. Such a confession is inadmissible in evidence against the accused. On the alibi of the accused-appellant: The Court rejected the defense of alibi because the distance between his claimed location and the crime scene was not so great as to preclude his physical presence. For an alibi to prosper, it must be shown that the accused was so far away that it was impossible for him to have been present at the crime scene. Alibi cannot prevail over positive identification by the victim and eyewitnesses. On the qualification of treachery: The Court affirmed the finding that the crime was murder due to treachery. The evidence showed that the accused-appellant positioned himself to allow the victim to approach before suddenly emerging and firing. This afforded the victim no opportunity to defend himself or retaliate, and the means of execution were deliberately adopted. Treachery can be present even in a frontal attack if it is sudden and without provocation, catching the victim unawares. On the damages: The Court affirmed the award of P50,000.00 as indemnity for the heirs of the victim and ordered the accused-appellant to pay an additional P50,000.00 as moral damages.
Main Doctrine
The Court affirmed the conviction for murder, holding that treachery was present in the manner of the attack, and that the victim's dying declaration, corroborated by eyewitness testimony, was sufficient for conviction despite the accused's alibi. The Court also reiterated the inadmissibility of confessions obtained in violation of Miranda rights.