People v. Avillana
REITERATIONFacts
The Antecedents: On May 19, 1992, between 10:00 and 11:00 in the evening, Andresito Sinsoro, Arnold Fabello, and Romeo Cabigting were walking side by side in front of the Star Elementary School, Bagong Silang, Caloocan City, waiting for a jeepney. The accused, Romulo Avillana y Catascan, approached from behind, took an extra step, and stabbed Andresito in the chest with an 8-inch knife. Romeo Cabigting tried to help Andresito, but the accused then turned his attention to Romeo, who let go of Andresito and fled. Arnold Fabello also fled when the accused intended to attack him next. Fabello informed Andresito's wife, Conchita Sinsoro, of the incident. Andresito was brought to Tala Hospital but died around 1:00 a.m. the following day. Conchita and Fabello reported the death to the police. Procedural History: The Regional Trial Court (RTC), Branch 121, Kalookan City, convicted Romulo Avillana y Catascan of murder and sentenced him to reclusion perpetua, with various damages. The accused appealed the decision. The Petition: The accused-appellant asserted his innocence, claiming his guilt was not proven beyond reasonable doubt and that his alibi should have been given credence.
Issue(s)
Whether the guilt of the accused-appellant was proven beyond reasonable doubt. Whether treachery attended the commission of the crime. Whether the awarded damages were supported by evidence.
Ruling
The Supreme Court affirmed the conviction of the accused-appellant for murder but modified the award of actual damages. The accused-appellant was sentenced to reclusion perpetua and ordered to pay the heirs of the victim P15,233.24 as actual damages, P50,000.00 as civil indemnity, and P50,000.00 as moral damages.
Ratio Decidendi
On the issue of guilt beyond reasonable doubt: The Court gave full faith and credit to the testimony of the sole prosecution eyewitness, Arnold Fabello. The Court reiterated the principle that witnesses are weighed, not numbered, and the testimony of a single credible witness can be sufficient for conviction. The Court found Fabello's testimony consistent and straightforward, even under cross-examination. The well-lighted crime scene allowed for positive identification, and no improper motive was attributed to Fabello for implicating the accused. The Court found the accused-appellant's alibi weak in the face of positive identification by a credible witness. The Court also noted that the accused's house and the store were only a kilometer away from the crime scene, a distance that did not preclude his presence there. On the issue of treachery: The Court upheld the trial court's finding of treachery. The victim was caught by surprise and was defenseless when the accused approached from behind and stabbed him. The Court clarified that even if the attack was frontal, it could still be considered treacherous if it was sudden and unexpected, affording the victim no opportunity to defend himself. The stealthful approach from behind and the suddenness of the stabbing clearly demonstrated the presence of treachery, ensuring the commission of the crime without risk to the assailant. On the issue of awarded damages: The Court affirmed the awards for civil indemnity and moral damages, finding them consistent with prevailing jurisprudence. However, the Court modified the award for actual and compensatory damages. The Court ruled that actual damages must be supported by receipts. Out of the P54,000.00 awarded by the trial court, only P15,233.24 was supported by receipts (P14,000.00 for funeral services and P1,233.24 for a Meralco bill). Therefore, the award for actual damages was reduced to the substantiated amount.
Main Doctrine
The testimony of a single, trustworthy, and credible witness is sufficient to convict an accused beyond reasonable doubt. An alibi, to be credible, must not only show the accused was not at the scene of the crime but also that it was impossible for him to be there. Actual damages require proof of actual expenses through receipts.