People v. Alilin
REITERATIONFacts
The Antecedents: On September 19, 1996, at around 10:30 p.m., accused-appellant Ruel Alilin, together with the deceased Federico Calisaan (Rico), Armando Ramos, and Roderick Lomaan, engaged in a drinking spree. After finishing the gin, Armando, Roderick, and Rico decided to go home. As they walked away, Alilin suddenly stabbed Rico on the back. Rico fell to the ground. Alilin then moved towards Roderick, but turned back, grabbed Rico's shirt, and stabbed him several times on the front part of his body. Alilin then chased Armando and Roderick, who fled. Armando and Roderick rushed Rico to Fatima Hospital, which refused admission, and then to Jose Reyes Memorial Hospital, where Rico died the following day from the stab wounds. Procedural History: Accused-appellant Ruel Alilin was charged with Murder. The Regional Trial Court of Valenzuela, Branch 171, found him guilty beyond reasonable doubt of murder qualified by treachery, sentencing him to suffer the penalty of reclusion perpetua and to pay costs. He was also ordered to pay the heirs of the victim P21,125.00 for wake, burial, and funeral expenses, and P50,000.00 as death indemnity. The Petition: Accused-appellant Ruel Alilin appealed, alleging that the trial court erred in finding that treachery attended the commission of the crime, thus qualifying it to murder.
Issue(s)
Whether the trial court erred in finding that treachery attended the commission of the crime, thus qualifying the same to murder. Whether the penalty of reclusion perpetua was correctly imposed. Whether the awards for civil indemnity, actual damages, and moral damages were proper.
Ruling
The Supreme Court affirmed the decision of the Regional Trial Court, finding accused-appellant Ruel Alilin guilty beyond reasonable doubt of Murder, sentencing him to suffer the penalty of reclusion perpetua, and ordering him to pay the heirs of the deceased Federico Calisaan P50,000.00 as civil indemnity, P21,125.00 as actual damages, and P50,000.00 as moral damages.
Ratio Decidendi
On the presence of treachery: The Supreme Court held that treachery attended the killing, qualifying the crime to murder. Prosecution witnesses testified that the accused-appellant suddenly attacked the deceased from behind, giving the victim no opportunity to defend himself or retaliate. The Court emphasized that treachery requires the employment of means of execution that gives the attacked person no opportunity to defend himself or retaliate, and that such means were deliberately or consciously adopted. The fact that the victim was stabbed on the back, fell to the ground, and was then stabbed several times on the front part of his body while on the ground indubitably showed a deliberate and conscious intent to kill. The Court found no reason to disturb the trial court's findings of fact and evaluation of witnesses' credibility, as trial courts are in a better position to assess these matters. On the penalty imposed: Since treachery attended the killing, the lower court did not err in convicting the accused-appellant of Murder. The Court found no aggravating or mitigating circumstances present, thus affirming the trial court's imposition of the penalty of reclusion perpetua, which is the penalty for murder in the absence of such circumstances. On the awards for damages: The Court affirmed the award of P21,125.00 as actual damages, noting that this amount was the subject of stipulation between the parties. Civil indemnity ex delicto can be awarded without further proof other than the commission of the felony itself, and the conviction for murder justified the award of P50,000.00 as civil indemnity. Consistent with jurisprudence, the Court also awarded P50,000.00 as moral damages to the heirs of the deceased.
Main Doctrine
Treachery attended the killing, qualifying the crime to Murder, and the imposition of reclusion perpetua and damages was affirmed.