People v. Lao-as
REITERATIONFacts
The Antecedents: On December 24, 1988, the victim, Leonardo Bastuten, invited the accused-appellant Felixberto Lao-as, Armando Ramirez, Demetrio Candelisas, and a certain Lanchiola to his house in Marilao, Bulacan, for a Christmas celebration. A drinking session ensued from 4:00 PM on December 24 until 5:00 AM on December 25, 1988. The victim did not partake in the drinking and went to sleep around 10:00 PM. At approximately 5:30 AM on December 25, while the victim was outside his house, the appellant, who was drunk, without provocation and without a word, drew a knife from his sock and stabbed the victim. Armando Ramirez, who was nearby, parried a second thrust, sustaining a wound on his left thumb. The appellant then fled the scene. Demetrio Candalisas, who was resting inside the victim's house, heard the victim shout "pare, nasaksak ako." When asked who stabbed him, the victim identified the appellant. The victim was brought to the hospital, where he succumbed to septicemia and reversible shock due to the stab wounds on December 27, 1988. Procedural History: The accused-appellant was charged with murder. Upon arraignment, he pleaded not guilty. The prosecution presented Concepcion Bastuten (wife of the victim), Armando Ramirez (eyewitness), and Demetrio Candilosas. The defense presented the appellant and Bienvenido Porlaje. The Regional Trial Court of Bulacan, Branch 22, convicted the appellant of murder, sentencing him to reclusion perpetua and ordering him to pay P50,000.00 as indemnity with interest. The Petition: The accused-appellant appealed the RTC decision, arguing that the trial court erred in convicting him of murder and in not giving credit to the fact that there was no eyewitness to the killing and that no criminal intent was established. He contended that no one witnessed the stabbing and that he was merely defending himself during a fight where he did not stab the victim.
Issue(s)
Whether the guilt of the accused-appellant was proven beyond reasonable doubt. Whether the aggravating circumstance of treachery attended the commission of the crime. Whether the trial court erred in convicting the accused-appellant of murder.
Ruling
The Supreme Court affirmed the decision of the Regional Trial Court, finding the accused-appellant guilty beyond reasonable doubt of murder and sentencing him to reclusion perpetua. The Court ordered the appellant to pay P50,000.00 as death indemnity with 6% interest from the filing of the information until fully paid.
Ratio Decidendi
On the issue of guilt beyond reasonable doubt: The Court found that the prosecution sufficiently established the guilt of the accused-appellant beyond reasonable doubt. The testimony of Armando Ramirez, an eyewitness, positively identified the appellant as the assailant who stabbed the victim with a bladed instrument concealed in his sock. Ramirez's testimony was found credible and entitled to full faith and credit, as he was an unbiased witness and his account was not directly contradicted. Furthermore, the victim's statement to Demetrio Candilosas, identifying the appellant as his assailant, was admitted as either a dying declaration or as part of the res gestae. The Court emphasized that such an ante-mortem statement is evidence of the highest order, and even if not admitted as a dying declaration, it is admissible as part of the res gestae because it was made shortly after a startling occurrence under the influence thereof, leaving no opportunity for the victim to contrive his statement. The appellant's flight after the incident was also considered indicative of his guilt. On the presence of the aggravating circumstance of treachery: The Court found that the stabbing was attended by treachery (alevosia). The appellant attacked the victim suddenly and unexpectedly while the latter was descending from his house, unarmed, and without giving the slightest provocation. The appellant had concealed the weapon beforehand, and the victim could not have anticipated the attack, especially since he had just awakened after sleeping late on Christmas Eve. The Court reiterated that treachery exists when the attack is made on an unarmed victim who has not given provocation, and the attack is sudden and unexpected. Even a frontal attack can be considered treacherous if it is sudden and unexpected, and the victim is unarmed. On the conviction for murder: The presence of treachery qualified the offense to murder. The Court noted that dwelling was not an aggravating circumstance as the stabbing occurred outside the victim's house, and it was not alleged in the information. With treachery as a qualifying circumstance and no other aggravating or mitigating circumstances present, the penalty of reclusion perpetua was correctly imposed by the trial court. The Court rejected the appellant's inconsistent defenses of self-defense and accident, finding them mutually exclusive and unsupported by evidence. The defense witness's testimony was also found to be riddled with contradictions, undermining the appellant's claim of innocence.
Main Doctrine
The Court affirmed the conviction for murder, holding that the prosecution sufficiently established the guilt of the accused beyond reasonable doubt through eyewitness testimony, the victim's dying declaration admissible as part of the res gestae, and the accused's flight. The Court also found the aggravating circumstance of treachery to be present, qualifying the offense to murder.