People v. Godoy
REITERATIONFacts
The Antecedents: On January 29, 1994, in Sariaya, Quezon, Alexander Carandang was allegedly stabbed by Ireneo Godoy, along with three other unidentified individuals. Marlon Leonardo, an eyewitness, testified that he saw Ireneo Godoy stab Alexander Carandang on the chest while two other persons were holding Carandang's hands. Leonardo reported the incident to his grandmother and then accompanied Eddie Carandang to inform Fidela Carandang, Alexander's mother. Alexander Carandang was found dead later that evening. The post-mortem examination revealed a stab wound on the chest, with the cause of death being shock and severe hemorrhage. Arcadio Marasigan testified that Alexander Carandang had a fistfight with the Godoys earlier that day and was advised not to go out as the Godoys were looking for him. Procedural History: Accused-appellant Ireneo Godoy was charged with Murder under Article 248 of the Revised Penal Code. He pleaded not guilty. The Regional Trial Court of Lucena City, Branch 54, found him guilty beyond reasonable doubt and sentenced him to reclusion perpetua, with civil indemnity, actual and compensatory damages, loss of earning capacity, attorney's fees, and moral damages. Accused-appellant appealed the decision. The Petition: The accused-appellant argued that the trial court erred in giving full faith and credence to the testimonies of prosecution witnesses who were related to the victim, in finding him guilty of murder, and in awarding damages.
Issue(s)
Whether the trial court erred in giving full faith and credence to the testimonies of prosecution witnesses who are related by blood to the victim, and whether the trial court erred in finding the accused-appellant guilty beyond reasonable doubt of the crime of Murder. Whether the trial court erred in the award of damages.
Ruling
The Supreme Court affirmed the conviction of accused-appellant Ireneo Godoy for Murder with modification on the award of damages. The Court found that the eyewitness testimony was credible despite the relationship of the witness to the victim, and that the defenses of alibi and denial were weak and unsubstantiated. While treachery was not appreciated, abuse of superior strength was considered an aggravating circumstance. The award for damages was modified based on the evidence presented and established jurisprudence.
Ratio Decidendi
On the credibility of prosecution witnesses and the guilt of the accused-appellant for Murder: The Court reiterated the rule that the factual findings of the trial judge are entitled to respect and even finality, as the judge had the opportunity to observe the demeanor of the witnesses. Mere relationship of the witnesses to the victim does not impair their credibility, especially when no improper motive can be ascribed to them. The Court found the testimony of Marlon Leonardo to be straight and categorical, thus worthy of credence. The Court also noted that the defense of alibi and denial are intrinsically weak defenses that cannot prevail over positive identification. The Court affirmed the conviction for Murder. While the trial court erred in appreciating the aggravating circumstance of treachery due to the lack of evidence that the mode of execution was deliberately and consciously adopted, the aggravating circumstance of abuse of superior strength was appreciated. This was based on the fact that five persons, including the accused-appellant, ganged up on the victim, with two holding his hands while the accused-appellant stabbed him, clearly indicating that the aggressors took advantage of their combined strength. The Court also found that conspiracy attended the commission of the crime, as evidenced by the concerted acts of the accused to achieve a common criminal objective. On the award of damages: The Court modified the award of damages. The P50,000.00 civil indemnity was affirmed. The moral damages were increased to P50,000.00. The actual damages were reduced to P26,500.00, as this was the amount substantiated by receipts, emphasizing that actual damages must be proved with reasonable certainty. The award for lost income was increased to P70,666.66, based on the formula for net earning capacity and the victim's daily earnings. The P5,000.00 attorney's fees were sustained.
Main Doctrine
While treachery could not be appreciated due to lack of evidence that the mode of execution was deliberately adopted, abuse of superior strength was appreciated due to the concerted action of five persons against one victim. Alibi and denial cannot prevail over positive identification. The award for damages was modified based on evidence and established jurisprudence.