People v. Muerong
REITERATIONFacts
The Antecedents: On January 13, 1996, at around 8:30 PM in Brgy. Tangcarang, Gerona, Tarlac, accused-appellant Fernando Muerong y Fajardo stabbed Rudy Pascua with a kitchen knife, hitting him on the left chest, which caused his death while en route to the hospital. The prosecution presented evidence that the victim and his companions were drinking gin at a wedding celebration. The accused joined them, and on two occasions, poured the remaining liquor from the drinking glass onto the victim's head. Thereafter, the accused was brought home. About an hour later, the accused returned unnoticed and stabbed the victim from behind. The victim died of hemorrhagic shock due to a stab wound. Procedural History: The Regional Trial Court (RTC), Branch 63, Tarlac, Tarlac, found the accused-appellant guilty beyond reasonable doubt of murder and sentenced him to suffer the penalty of reclusion perpetua, and to indemnify the heirs of Rudy Pascua in the amount of P50,000.00. The Petition: The accused-appellant appealed the RTC decision, arguing that the killing was not attended by treachery and evident premeditation, and thus should only be considered homicide.
Issue(s)
Whether the killing was attended by treachery. Whether the killing was attended by evident premeditation. Whether the accused-appellant is entitled to the mitigating circumstance of intoxication.
Ruling
The Supreme Court affirmed the decision of the RTC, finding the accused-appellant guilty of murder. The penalty of reclusion perpetua was upheld, with the modification that the accused-appellant was ordered to pay moral damages in the amount of P50,000.00 to the heirs of the victim, in addition to the civil indemnity of P50,000.00.
Ratio Decidendi
On the issue of treachery: The Court held that treachery was present. Treachery requires the employment of means, methods, or forms in the execution of the crime which tend directly and specially to insure its execution without risk to the offender. This includes the sudden and unexpected attack by the aggressor on an unsuspecting victim, depriving the latter of any real chance to defend himself. The Court found that the accused-appellant stabbed the victim from behind, holding his hair, which offered no risk to the offender and deprived the victim of any opportunity to defend himself or retaliate. The argument that the victim was forewarned by the earlier incident of pouring gin was dismissed, as the decisive factor is the manner of the attack itself, which made defense impossible. The prosecution witnesses' testimonies were given credence over the uncorroborated testimony of the appellant. On the issue of evident premeditation: The Court noted that the RTC did not make a finding of evident premeditation, and the prosecution failed to prove its elements: the time the offender determined to commit the crime, an act indicating adherence to that determination, and a sufficient lapse of time for reflection. Therefore, evident premeditation could not be considered against the appellant. On the issue of intoxication: The Court ruled that intoxication could only be a mitigating circumstance if it was not habitual or subsequent to a plan to commit the crime, and if the quantity consumed blurred the accused's reason and deprived him of control. While the appellant testified to drinking several glasses of gin, the Court found it was not sufficiently established that the quantity caused obfuscation and loss of control. The fact that he returned after an hour and committed the treacherous act indicated a degree of reflection and control, negating the claim for mitigation.
Main Doctrine
Treachery exists when the attack is sudden, unexpected, and initiated from behind, rendering the victim no opportunity to defend himself, thus qualifying the crime to murder. Intoxication is not a mitigating circumstance unless it is not habitual or subsequent to a plan, and the quantity consumed blurs reason and deprives control.