People v. Cariño
REITERATIONFacts
The Antecedents: The accused-appellant, Pedro Cariño, was charged with murder for allegedly killing Edmundo Milan on September 16, 1992. The prosecution alleged that the killing was committed with treachery and evident premeditation. The incident stemmed from a misunderstanding at a wake where the victim, Edmundo Milan, touched the accused's head, leading to an argument. The accused allegedly pursued the victim after the latter decided to go home, stabbed him twice in the back, and then hacked him on the head. The victim was pronounced dead on arrival at the hospital. Procedural History: The Regional Trial Court (RTC) of Candon, Ilocos Sur, found the accused guilty of murder and sentenced him to reclusion perpetua, ordering him to pay civil indemnity and burial expenses. The accused appealed the decision. The Petition: The accused-appellant assigned two errors: (1) the RTC erred in giving credence to the testimony of Rolando Lovinaria, the victim's brother-in-law, and (2) the RTC erred in finding that treachery qualified the killing.
Issue(s)
Whether the testimony of prosecution witness Rolando Lovinaria deserves credence. Whether self-defense was proved by the appellant. Whether treachery qualified the killing of Edmundo Milan to murder.
Ruling
The Supreme Court affirmed the RTC decision with modification. It found the appellant guilty of homicide, not murder, and sentenced him to an indeterminate penalty. The awarded damages were also modified.
Ratio Decidendi
On the credibility of Rolando Lovinaria: The Court held that mere relationship to the victim does not automatically impair a witness's credibility. It noted that the trial court is in a better position to assess credibility. The Court found no improper motive for Rolando Lovinaria to testify falsely and considered his testimony candid and credible. The Court found no unbelievable aspects in his account, including the victim's reaction after the appellant broke free from Rolando's embrace, deeming it largely irrelevant to the offense charged. On self-defense: The Court ruled that the requisites for self-defense were not established. It found no proof of unlawful aggression on the part of the victim. The claim that the victim pulled out a knife was uncorroborated, and the appellant's assertion of wrestling the knife away was self-serving. The Court highlighted that the appellant followed the victim, persisted in confronting him despite intercession, and the autopsy revealed multiple wounds, some inflicted from behind, which contradicted the claim of self-defense. The appellant's actions were deemed belligerent, not defensive. On treachery: The Court agreed with the Office of the Solicitor General that treachery was not conclusively established. It reiterated the requisites for treachery: the victim's inability to defend himself and the conscious adoption of means to ensure the attack's success. The Court found that the victim was put on guard by the prior heated argument and the appellant's pursuit. The victim's facial injuries indicated he was able to fight back, negating the element of surprise or the victim's inability to defend himself. Therefore, treachery did not qualify the killing to murder.
Main Doctrine
The Court modified the RTC decision, finding the accused guilty of homicide instead of murder due to the absence of treachery, and adjusted the awarded damages.