People v. Surongon
REITERATIONFacts
The Antecedents: On March 22, 1998, at around 4:00 p.m., Allan Viduya, a 15-year-old student, was watching a basketball game in Antipolo City. The accused-appellant, Dominador D. Surongon, arrived, positioned himself behind Allan, and stabbed him twice in the back with a knife. Allan was brought to Padilla Hospital but was pronounced dead on arrival. The medico-legal officer testified that Allan died of hemorrhage due to two stab wounds, one of which was fatal, and noted the absence of defense wounds, suggesting the victim was unaware of the attack. The victim's mother testified to incurring significant funeral and burial expenses. Procedural History: An Information for Murder was filed against Dominador D. Surongon. After trial, the Regional Trial Court (RTC) of Antipolo City found the appellant guilty beyond reasonable doubt of Murder, qualified by treachery, and sentenced him to reclusion perpetua. The Court of Appeals (CA) affirmed the RTC decision with modification, awarding civil indemnity, moral damages, and exemplary damages to the victim's heirs. The Petition: The accused-appellant appealed to the Supreme Court, arguing that his guilt was not proven beyond reasonable doubt.
Issue(s)
Whether the guilt of the accused-appellant for the crime of Murder was proven beyond reasonable doubt. Whether the killing was attended by the qualifying circumstance of treachery. Whether the accused-appellant is liable for damages.
Ruling
The Supreme Court affirmed the decision of the Court of Appeals with modification, finding the accused-appellant guilty of Murder and sentencing him to reclusion perpetua. The Court also ordered the accused-appellant to pay additional temperate damages to the heirs of the victim.
Ratio Decidendi
On whether the guilt of the accused-appellant for the crime of Murder was proven beyond reasonable doubt: The Court held that the guilt of the accused-appellant was proven beyond reasonable doubt. This was based on the positive identification of the accused by two eyewitnesses, Sonny Campita and Ernie Manatlao, who were present during the stabbing incident. The witnesses testified that they recognized the appellant as he approached the victim and subsequently stabbed him twice in the back. The Court found that these eyewitnesses had no motive to falsely testify against the appellant. Furthermore, the appellant's defense of alibi was found to be weak and uncorroborated. The appellant claimed to be at his cousin's house having a drinking spree, but the distance between his alleged location and the crime scene was only about a 30-minute drive, making it physically possible for him to be present at the scene. The Court also considered the appellant's flight to the province after learning of the accusation as an indication of guilt, stating that an innocent person would have surrendered to clear their name. The Court cited the Holy Scripture, "the guilty fleeth but the innocent is as bold as the lion," to emphasize this point. The positive identification by credible witnesses, coupled with the weakness of the alibi and the evidence of flight, established the appellant's culpability beyond reasonable doubt. On whether the killing was attended by the qualifying circumstance of treachery: The Court affirmed the finding of treachery as a qualifying circumstance. Treachery is defined as the sudden and unexpected attack on an unsuspecting victim, which deprives the victim of the opportunity to defend himself or repel the aggression, thereby ensuring the commission of the crime without risk to the aggressor and without provocation from the victim. In this case, Allan Viduya was watching a basketball game and was unaware of the impending attack from behind. The medico-legal officer's testimony that there were no defense wounds on the victim's body further supported the conclusion that Allan was defenseless and unaware of the attack. The stabbing occurred from behind, preventing Allan from defending himself or retaliating. Therefore, the attack was executed in a manner that consciously and deliberately adopted by the appellant to ensure the commission of the crime without risk to himself, thus qualifying the offense to Murder. On whether the accused-appellant is liable for damages: The Court affirmed the awards made by the Court of Appeals for civil indemnity, moral damages, and exemplary damages. Additionally, the Court awarded temperate damages in the amount of ₱25,000.00. This was based on the testimony of the victim's mother regarding funeral and burial expenses amounting to ₱69,000.00, for which receipts were not presented. The Court reasoned that while the exact amount of actual damages could not be determined due to the lack of receipts, it was undeniable that the victim's heirs suffered pecuniary loss. Under Article 2224 of the Civil Code, temperate damages may be awarded when the exact amount of loss cannot be proved with certainty but it is evident that loss has been incurred. The Court cited its ruling in People v. Abrazaldo where temperate damages were fixed at ₱25,000.00 in similar circumstances. Thus, the accused-appellant was ordered to pay the heirs of the victim the sum of ₱50,000.00 as civil indemnity, ₱50,000.00 as moral damages, ₱25,000.00 as exemplary damages, and ₱25,000.00 as temperate damages.
Main Doctrine
The positive identification of the accused by eyewitnesses, coupled with the absence of motive to falsely testify, negates the defense of alibi. Furthermore, flight from the scene of the crime or after being accused is indicative of guilt. Treachery is present when the attack is sudden and unexpected, depriving the victim of the opportunity to defend himself.