People v. Anilao
REITERATIONFacts
The Antecedents: Petitioner Rammel Monares Anilao alias Jojo was charged with Frustrated Murder for allegedly attacking and stabbing Ronald Apud with a bladed instrument, inflicting a stab wound that would have caused death but for timely medical assistance. The Information alleged intent to kill, evident premeditation, and treachery. Procedural History: The Regional Trial Court (RTC) of Isulan, Sultan Kudarat found petitioner guilty of frustrated homicide, not frustrated murder, as evident premeditation and treachery were not duly proven. The RTC sentenced petitioner to an indeterminate penalty and ordered him to pay actual, moral, and exemplary damages. The Court of Appeals (CA) affirmed the RTC decision, and a subsequent motion for reconsideration was denied. The Petition: Petitioner sought review of the CA decision, arguing that the CA failed to apply the equipoise doctrine, did not consider his brief, and failed to appreciate facts that could lead to his acquittal. He contended that the evidence did not create moral certainty of his guilt.
Issue(s)
Whether the Court of Appeals erred in failing to apply the equipoise doctrine and in failing to appreciate facts that could lead to petitioner's acquittal. Whether the Court of Appeals denied petitioner due process by not considering his brief. Whether petitioner is guilty beyond reasonable doubt of frustrated homicide. Whether the penalty and damages awarded were proper.
Ruling
The petition is denied. The Decision of the Court of Appeals is affirmed with modification. Petitioner Rammel Monares Anilao alias Jojo is found guilty beyond reasonable doubt of the crime of Frustrated Homicide and is penalized with an indeterminate prison term ranging from four (4) years, two (2) months and one (1) day of prision correccional, as minimum, to eight (8) years and one (1) day of prision mayor, as maximum. He is ordered to pay Ronald Apud actual damages in the amount of ₱24,541.50 and moral damages in the amount of ₱6,000.00. The award of exemplary damages was deleted.
Ratio Decidendi
On the failure to apply the equipoise doctrine and appreciation of facts: The Court found petitioner's arguments without merit. Petitioner admitted his presence at the scene but denied the commission of the crime, pointing to another person named Joe. Mere denial, especially when not corroborated, cannot prevail over credible positive testimonies. The Court agreed with the OSG that the location of the wound did not negate petitioner's culpability, as eyewitnesses positively identified him. The circumstances petitioner relied upon were minor points that could not overcome the straightforward testimonies of the private complainant and other eyewitnesses who had no ulterior motive. The trial court's evaluation of witness testimony is accorded great respect and finality. On the denial of due process: The Court found that the CA did consider the Appellant's Brief filed by petitioner's private counsel, as evidenced by a prior resolution denying a motion to expunge it. Therefore, the contention of denial of due process on this ground was unsubstantiated. On the guilt of frustrated homicide: The Court affirmed the trial court's finding that petitioner was guilty beyond reasonable doubt of frustrated homicide. A felony is frustrated when the offender performs all the acts of execution which would produce the felony as a consequence but which do not produce it by reason of causes independent of the will of the perpetrator. The evidence presented, particularly the positive identification by eyewitnesses, established petitioner's commission of the crime. On the penalty and damages: The trial court correctly found petitioner guilty of frustrated homicide. The penalty imposed was an indeterminate prison term ranging from four (4) years, two (2) months and one (1) day of prision correccional, as minimum, to eight (8) years and one (1) day of prision mayor, as maximum. The award of actual and moral damages was upheld. However, the award of exemplary damages was deleted because the trial court found no aggravating or mitigating circumstances attending the commission of the crime, and exemplary damages are only imposed when the crime was committed with aggravating circumstances.
Main Doctrine
Mere denial by an accused, especially when not corroborated or substantiated by clear and convincing evidence, cannot prevail over the testimony of credible witnesses who testify on affirmative matters. Positive and forthright declarations of witnesses are often held to be worthier of credence than the self-serving denial of an accused. The trial court's evaluation of the testimony of the witnesses is accorded great respect and finality in the absence of any indication that it overlooked certain facts or circumstances of weight and influence.