People v. Caritativo
REITERATIONFacts
The Antecedents: On April 28, 1995, at around 3:30 a.m., in Sitio Bulangcog, Barangay Iriron, Calintaan, Occidental Mindoro, during a wedding reception, two individuals, Expidito "Freddie" Mariano and Marlon Trambulo, were stabbed while sleeping inside a parked passenger jeep. Freddie Mariano sustained a fatal stab wound to the chest, while Marlon Trambulo was seriously wounded. The accused, Larry Caritativo, was identified by eyewitness Expedito Prado as the assailant who entered the jeep and stabbed the victims. Prosecution witness Catalino Gonzales testified that the appellant confessed to him about the stabbing and that he noticed blood on the appellant's shirt. Procedural History: The Regional Trial Court of San Jose, Occidental Mindoro, Branch 46, found the appellant, Larry Caritativo, guilty beyond reasonable doubt of murder and sentenced him to suffer the supreme penalty of death. The court also ordered him to indemnify the heirs of Freddie Mariano. The Petition: The appellant appealed the decision, arguing that the trial court erred in finding him guilty of murder and in imposing the death penalty. He questioned the credibility of the prosecution witnesses, particularly Expedito Prado and Catalino Gonzales, and insisted on his alibi.
Issue(s)
Whether the trial court erred in finding the accused-appellant guilty beyond reasonable doubt of the crime of murder. Whether the trial court gravely erred in imposing the supreme penalty of death; and the propriety of the award of damages.
Ruling
The Supreme Court affirmed the conviction of the appellant for murder but modified the penalty to reclusion perpetua. The award for damages was also modified.
Ratio Decidendi
On the issue of guilt for murder: The Court found the evidence of guilt to be sufficient. The testimony of eyewitness Expedito Prado positively identified the appellant as the assailant who stabbed the victims while they were sleeping inside the jeep. This identification was bolstered by the fact that Prado knew the appellant for a long time and that the crime scene was adequately illuminated by the dance hall lights. Furthermore, Catalino Gonzales testified that the appellant confessed his guilt to him, which is admissible as an admission against interest under Section 26, Rule 130 of the Rules of Court. The Court found no improper motive for these witnesses to testify falsely against the appellant. The defense of alibi offered by the appellant was deemed weak and unconvincing, especially given its inconsistencies and the proximity of the supposed alibi location to the crime scene. The Court reiterated that alibi cannot prevail over positive identification by credible witnesses. On the imposition of the death penalty and the award of damages: The Court ruled that while treachery attended the commission of the crime, qualifying it to murder, it could not be used again as an aggravating circumstance to impose the death penalty. Under Article 63 of the Revised Penal Code, the death penalty can only be imposed if there is at least one aggravating circumstance. Since treachery was already used to qualify the crime to murder, and no other aggravating circumstance was proven, the lesser penalty of reclusion perpetua should be imposed. The Court cited jurisprudence holding that treachery, once used to qualify an offense, cannot be considered again as an aggravating circumstance for the purpose of imposing a higher penalty. The Court modified the award of damages. It deleted the award of actual damages for lack of receipts to substantiate the claimed expenses. Moral damages were awarded in the amount of P50,000, which is standard jurisprudence for death caused by crime. Temperate damages of P25,000 were granted, recognizing that expenses for burial and wake were reasonably incurred, even without receipts. The civil indemnity ex delicto was reduced to P50,000, consistent with current jurisprudence for murder cases.
Main Doctrine
The defense of alibi is weak against positive identification by a credible eyewitness and an admission of guilt. Treachery qualifies the crime to murder, but it cannot be used again as an aggravating circumstance to impose the death penalty when no other aggravating circumstance exists. Damages must be proven with receipts, or temperate damages may be awarded.