People v. Alabado
REITERATIONFacts
The Antecedents: On May 10, 2000, in Mandaluyong City, two separate Informations were filed against Randy Alabado y David for Murder (Criminal Case No. MC-00-2508-H) and Frustrated Murder (Criminal Case No. MC-00-2509). The Information for Murder alleged that Alabado, armed with a kitchen knife, with intent to kill, evident premeditation, and treachery, stabbed Ricardo Ampaya y Mateo, causing his death. The Information for Frustrated Murder alleged that Alabado, armed with a kitchen knife, with intent to kill, evident premeditation, and treachery, attacked and stabbed Evelyn Ampaya y Dizon, inflicting injuries that would ordinarily cause death, but which did not result in death due to timely medical attendance. Procedural History: The accused pleaded not guilty in both cases, and a joint trial ensued. The Regional Trial Court (RTC) of Mandaluyong City, Branch 24, found the accused guilty beyond reasonable doubt in both cases. In Criminal Case No. MC-00-2508-H, he was sentenced to suffer reclusion perpetua and ordered to pay damages to the heirs of Ricardo Ampaya. In Criminal Case No. MC-00-2509, he was sentenced to an indeterminate penalty of nine (9) years of prision mayor to fifteen (15) years of reclusion temporal and ordered to pay damages to Evelyn Ampaya. On appeal to the Court of Appeals (CA), the judgment of conviction was affirmed with modifications regarding the award of damages. The CA found the accused guilty of murder qualified by treachery and frustrated murder. The Petition: The accused-appellant appealed to the Supreme Court, questioning the appellate court's decision and assigning errors concerning the trial court's full credence to prosecution witnesses' testimonies, the appreciation of treachery, and the failure to consider intoxication as a mitigating circumstance.
Issue(s)
Whether the trial court erred in giving full credence to the testimonies of the prosecution witnesses and whether the appellant was sufficiently and positively identified by the prosecution witnesses as the perpetrator of the crimes. Whether the trial court erred in appreciating the qualifying circumstance of treachery. Whether the trial court erred in failing to consider intoxication as a mitigating circumstance and the defense of alibi.
Ruling
The Supreme Court affirmed the decision of the Court of Appeals in all respects, upholding the conviction of the accused-appellant for murder and frustrated murder. The penalties and damages awarded by the appellate court were sustained.
Ratio Decidendi
On the sufficiency of identification and credibility of prosecution witnesses: The Court found that the prosecution had discharged its burden of identification. The testimonies of the principal prosecution witnesses were found to be credible, and there was no evidence of ill-motive to falsely impute the crimes upon the appellant. The Court emphasized that Evelyn Ampaya, who was well-acquainted with the appellant (as he was the brother of her fiancé and a long-time boarder), was able to identify him despite the low lighting conditions in her room. Her identification was further strengthened by the fact that she was able to recognize him holding a knife and subsequently being attacked by him. The Court noted that startling occurrences often create indelible impressions, making the identification reliable. The testimony of Evelyn was corroborated by other witnesses, including her father Ricardo Ampaya, who called out to the appellant by name, and her brother Edgar Ampaya, who witnessed the appellant stabbing their father. The Court gave significant weight to the trial court's assessment of the witnesses' credibility, demeanor, and spontaneity. On the appreciation of treachery: The Court affirmed the finding of treachery in both the murder of Ricardo Ampaya and the frustrated murder of Evelyn Ampaya. It reiterated the established jurisprudence that an attack on a victim who has just awakened or roused from sleep is attended by treachery, as the victim is in no position to defend themselves. Both Evelyn and Ricardo were attacked shortly after being roused from sleep due to the appellant's intrusion. Evelyn was attacked from behind while trying to flee, and Ricardo was attacked when he came out to investigate the commotion. The Court found that the appellant's unexpected and unauthorized intrusion into Evelyn's room while she was asleep, and the subsequent attack on Ricardo who was caught unaware, ensured the execution of the crimes without risk to the appellant. The fact that the victims knew and trusted the appellant for years prior to the incident did not negate treachery, as they could not have foreseen the deadly assault. On the defense of intoxication and alibi: The Court rejected the appellant's claim of intoxication as a mitigating circumstance. It held that intoxication is mitigating only if it is not habitual nor intentional and must be indubitably proven. The appellant failed to prove this, especially since his defense was primarily alibi and claimed unconsciousness. The Court found the appellant's claim of unconsciousness to be a convenient excuse, lacking convincing evidence beyond his self-serving statement. The Court noted that if a blow to the head occurred, it likely happened after the stabbing rampage and during the struggle for the knife, not before or during the commission of the crimes. The Court reiterated that positive testimony from credible witnesses prevails over unsubstantiated denials and alibis.
Main Doctrine
Positive identification of the accused by credible witnesses, even under less than ideal lighting conditions, prevails over the defense of alibi or denial, especially when the accused is well-acquainted with the victim. Intoxication is not a mitigating circumstance if not proven to be neither habitual nor intentional, and is antithetical to a defense of alibi or unconsciousness.