People v. Alfon
REITERATIONFacts
The Antecedents: On February 18, 1993, at around 2:00 p.m., in Barangay Oring, Caramoan, Camarines Sur, Expedito Alfon allegedly followed the victim, Tomas Alferez, and from behind, stabbed him twice with a fan knife (balisong). The victim sustained two stab wounds, one on the left lower rib and another on the right side of the chest, which caused his instantaneous death. An incised wound was also found on the victim's right index finger. Procedural History: Appellant Expedito Alfon was charged with murder. He pleaded not guilty. After trial, the Regional Trial Court (RTC) of San Jose, Camarines Sur, Branch 30, found him guilty of murder and sentenced him to suffer the penalty of reclusion perpetua, to indemnify the heirs of the victim P50,000.00 as civil indemnity and P24,220.00 as actual damages, and to pay the costs. The Petition: Expedito Alfon appealed the RTC decision, assigning several errors, including the trial court's reliance on prosecution witnesses' testimonies, the qualification of the killing by treachery, the rejection of his defense that Rodolfo Alferez stabbed the victim, and the award of actual damages.
Issue(s)
Whether the trial court erred in giving full faith and credit to the testimonies of the prosecution witnesses and in rejecting the defense. Whether the killing of Tomas S. Alferez was qualified by treachery. Whether the trial court erred in not acquitting accused-appellant despite the prosecution's failure to prove his guilt beyond reasonable doubt. Whether the trial court erred in holding accused-appellant liable for actual damages in the amount of P24,220.00. On the penalty.
Ruling
The Supreme Court affirmed the conviction of Expedito Alfon for murder but modified the award of damages. The Court deleted the award of actual damages and, in lieu thereof, awarded P25,000.00 as temperate damages and P25,000.00 as exemplary damages, in addition to the P50,000.00 civil indemnity.
Ratio Decidendi
On the issue of the trial court's faith and credit to prosecution witnesses' testimonies and the rejection of the defense: The Court found the eyewitness testimonies of Vicente Eusebio and Manuel Rayoso to be credible and convincing. Their accounts consistently established that the appellant followed the victim from behind and suddenly stabbed him. The appellant's argument that the injuries being on the front of the victim contradicted an attack from behind was refuted by the detailed demonstration and testimony explaining how the attack, initiated from behind, resulted in frontal wounds. The Court also addressed the alleged conflicting testimonies regarding the number of stab wounds, holding that minor inconsistencies do not impair credibility, especially when the principal occurrence and identification of the assailant are consistent. The Court found the appellant's defense of denial and his version of events, where Rodolfo Alferez mistakenly stabbed the victim, to be doubtful and unsubstantiated. The eyewitnesses confirmed Rodolfo was not present, the physical evidence of three injuries (including one on the finger) remained unexplained by the appellant's version, there was no established ill-motive, and crucially, the appellant failed to present independent evidence to support his denial. On the issue of treachery: The Court affirmed that treachery attended the commission of the crime. The essence of treachery lies in the unexpected and sudden attack that renders the victim unable to defend himself. The Court clarified that this criterion applies regardless of whether the attack is frontal or from behind. In this case, the appellant came from behind, held the victim's shoulder, and suddenly stabbed him. The victim was unarmed and unsuspecting, making him unable to defend himself. The appellant consciously adopted a means of attack by surreptitiously following the victim with a weapon, ensuring the execution of the act and the victim's death. The location of the wounds on the front of the body did not negate treachery, as the attack was sudden and from behind, preventing any defense. The trial court did not err in not acquitting accused-appellant despite the prosecution's failure to prove his guilt beyond reasonable doubt because the evidence presented sufficiently established his guilt. On the issue of damages: The Court found that the trial court erred in awarding actual damages of P24,220.00 due to insufficient proof. The prosecution presented only the testimony of the victim's heir and a list of expenses without supporting receipts. However, acknowledging that pecuniary loss was suffered, the Court awarded P25,000.00 as temperate damages. Furthermore, given the presence of treachery, the Court granted P25,000.00 as exemplary damages. The P50,000.00 civil indemnity awarded by the trial court was sustained. On the penalty: The Court found the appellant guilty of murder. Since the crime was committed before the effectivity of Republic Act No. 7659 (the New Death Penalty Law), the penalty under Article 248 of the Revised Penal Code prior to its amendment was reclusion temporal in its maximum period to death. As there were no mitigating or aggravating circumstances, the penalty of reclusion perpetua imposed by the trial court was deemed correct.
Main Doctrine
Treachery can attend a crime even if the wounds are inflicted on the front of the victim, provided the attack is sudden, unexpected, and the victim is unable to defend himself. Inconsistent details in eyewitness testimonies do not necessarily impair credibility if the principal occurrence and assailant identification are consistent. Denial, to be credible, must be supported by strong evidence of non-culpability.