People v. Dela Cruz
REITERATIONFacts
The Antecedents: The case originated from an Information filed on December 28, 1998, charging Roger Dela Cruz y Doe with Murder. The prosecution alleged that on August 29, 1998, at approximately 10:00 p.m. in Barangay Cabanbanan, Calabanga, Camarines Sur, the accused, armed with an icepick and with intent to kill, treacherously attacked and fatally stabbed Mark Lester Resterio Suarez in the chest, causing his death. Procedural History: The accused pleaded not guilty upon arraignment. The prosecution presented witnesses Joseph Sanchez, Milagros Suarez, and Felix delos Santos, who testified regarding the stabbing incident and the victim's dying statement identifying the accused. Dr. Daniel Y. Tan testified on the necropsy findings. The appellant presented a defense of denial and alibi, corroborated by his mother and a friend. The Regional Trial Court of Calabanga, Camarines Sur, Branch 63, found the appellant guilty of Murder and sentenced him to reclusion perpetua, with civil and moral damages. This decision was appealed to the Supreme Court. The Petition: The appellant filed an appeal before the Supreme Court, assigning as errors the trial court's full faith and credence to prosecution witnesses, the appreciation of treachery, and the finding of guilt for Murder. The Supreme Court, while affirming the guilt of the accused, modified the conviction to Homicide. The Court found that treachery was not sufficiently established, thus reducing the crime. The sentence was modified to an indeterminate penalty, and temperate damages were awarded in addition to civil and moral damages.
Issue(s)
Whether the trial court gravely erred in giving full faith and credence to the testimonies of prosecution witnesses Joseph Sanchez and Felix delos Santos, and the admissibility of the victim's statement. Whether the trial court gravely erred in appreciating the qualifying circumstance of treachery. Whether the trial court gravely erred in finding the accused-appellant guilty beyond reasonable doubt of the crime of Murder, and the defenses of denial and alibi, penalty, and damages.
Ruling
The Supreme Court modified the decision of the Regional Trial Court. The appellant, Roger Dela Cruz y Doe, was found guilty of Homicide, not Murder. He was sentenced to suffer the indeterminate penalty of eight (8) years and one (1) day of prision mayor, as minimum, to fourteen (14) years, eight (8) months and one (1) day of reclusion temporal, as maximum. He was ordered to pay the heirs of the deceased P50,000.00 as civil indemnity, P50,000.00 as moral damages, and P25,000.00 as temperate damages.
Ratio Decidendi
On the credibility of prosecution witnesses and the admissibility of the victim's statement: The Court held that the anti-mortem statement of the victim, "Roger," was not a dying declaration but was admissible as part of the res gestae. The requisites for res gestae were met: the stabbing was a startling occurrence, the statement was made before the victim had time to contrive, and it concerned the occurrence and its attending circumstances. The Court also reiterated the rule that the findings of the trial court on the credibility of witnesses are entitled to the highest respect and will not be disturbed on appeal absent clear showing of overlooked, misunderstood, or misapplied facts or circumstances. On the qualifying circumstance of treachery: The Court agreed with the appellant that the crime committed was not murder, as the qualifying circumstance of treachery was not sufficiently established. Treachery requires a sudden and unexpected attack that deprives the victim of any chance to defend himself, ensuring the commission of the crime without risk to the aggressor. Since the prosecution witness did not see the actual stabbing, there was no way to determine how the attack was initiated or if the appellant contemplated a mode to insure the killing without risk to himself. Therefore, treachery was not proven beyond reasonable doubt. On the defenses of denial and alibi, penalty and damages: The Court found the appellant's defenses of denial and alibi to be weak. Denial is intrinsically a weak defense requiring strong evidence of non-culpability, and alibi is viewed with suspicion and caution due to its susceptibility to fabrication. The Court gave more credence to the positive assertions of the prosecution witness who saw the appellant leaving the scene of the crime, over the appellant's negative averments. Furthermore, the appellant's flight from the scene and the delay in his arrest were considered indications of guilt. The Court ruled that the crime committed was homicide, punishable by reclusion temporal under Article 249 of the Revised Penal Code. In the absence of mitigating or aggravating circumstances, the penalty should be in its medium period. Applying the Indeterminate Sentence Law, the appellant was sentenced to an indeterminate penalty. The civil indemnity of P50,000.00 and moral damages of P50,000.00 were affirmed. The Court also awarded P25,000.00 as temperate damages in lieu of actual damages, citing jurisprudence that it is anomalous for heirs who proved less than P25,000.00 in actual damages to be in a worse situation than those who proved none but are entitled to temperate damages.
Main Doctrine
The Court modified the conviction from Murder to Homicide, finding that while the victim's dying declaration was admissible as part of the res gestae, the qualifying circumstance of treachery was not sufficiently established. The Court also affirmed the award of civil indemnity and moral damages, and awarded temperate damages in lieu of proven actual damages.