People v. Dela Cruz
REITERATIONFacts
The Antecedents: On August 7, 1995, at about 7:00 p.m., Rafael Santarin, Mario Pader, and Manny Viscaya were conversing near the barangay hall. Accused-appellant Rommel Dela Cruz, Santarin's first cousin, was standing behind them. Viscaya went to buy cigarettes and upon returning, saw Dela Cruz approach from behind and stab Santarin once in the back. Santarin fell and was brought to the hospital where he died due to the stab wound. Dr. Bienvenido Muñoz conducted the autopsy and found a 15-centimeter deep stab wound in the back, which caused Santarin's death. The weapon used was a sharp, pointed single-bladed instrument. Procedural History: Accused-appellant Dela Cruz was indicted for murder. He pleaded not guilty. The prosecution presented Viscaya and Dr. Muñoz as witnesses. Dela Cruz claimed denial and alibi, stating he was collecting fees and then slept in a parked jeep, later fleeing to Cebu and then Nueva Ecija. The Regional Trial Court (RTC) convicted Dela Cruz of murder and sentenced him to reclusion perpetua, with civil indemnity and funeral expenses. The case was elevated to the Court of Appeals (CA), which affirmed the RTC's decision with modification on the award of damages. Dela Cruz appealed to the Supreme Court. The Petition: Accused-appellant sought reversal of his conviction, arguing that the trial court erred in giving credence to the prosecution witness's testimony, that his guilt was not proven beyond reasonable doubt, and that the crime committed was homicide, not murder.
Issue(s)
Whether the trial court erred in giving full faith and credence to the testimony of the prosecution witness, and whether the guilt of the accused-appellant was proven beyond reasonable doubt. Whether the crime committed was homicide or murder, specifically regarding the presence and allegation of treachery. Whether the Information sufficiently alleged treachery as a qualifying circumstance for murder.
Ruling
The Supreme Court denied the petition and affirmed the decision of the Court of Appeals, upholding the conviction of Rommel Dela Cruz for murder.
Ratio Decidendi
On the credibility of the prosecution witness and proof beyond reasonable doubt: The Court held that positive identification of the accused by a credible witness prevails over denial and alibi. Manny Viscaya, who had known the accused for 15 years, positively identified Rommel Dela Cruz as the assailant. Although Viscaya did not see the weapon, his explanation that the incident happened too fast was accepted. The Court emphasized that witnesses are weighed, not numbered, and a single credible witness is sufficient for conviction. The Court found no improper motive for Viscaya to testify falsely against Dela Cruz. The accused's claim of misunderstanding with Viscaya was deemed flimsy. Furthermore, the Court noted that the conditions of visibility were favorable, and Viscaya was not shown to be biased. The Court also found Dela Cruz's denial and alibi to be unworthy of belief, especially since he admitted that the place where he slept was not far from the scene of the crime, making it physically possible for him to have committed the offense. The Court also considered his flight from the scene and subsequent evasion of arrest as strong indications of guilt. The Court stated that for alibi to prosper, the accused must establish that he was in another place and so far away that he could not have been physically present at the crime scene, which Dela Cruz failed to do. On the classification of the crime as murder and the presence of treachery: The Court reiterated the elements of murder: (1) that a person is killed; (2) that the accused killed him; (3) that the killing was attended by any of the qualifying circumstances in Article 248 of the Revised Penal Code; and (4) the killing is not parricide or infanticide. The Court found that treachery was present because the attack was sudden, unexpected, and from behind, giving the victim no opportunity to defend himself or retaliate. The means of execution were deliberately adopted by the accused to insure the commission of the crime without risk to himself. The autopsy finding of a stab wound in the back corroborated the testimony of Viscaya. The Court cited previous rulings where treachery was appreciated in similar circumstances of sudden and unexpected attacks from behind. On the sufficiency of the Information for murder: The Court rejected the appellant's contention that the Information did not sufficiently allege treachery as a qualifying circumstance. Citing People v. Aquino and People v. Lab-eo, the Court clarified that qualifying circumstances need not be preceded by descriptive words like "qualifying" or "qualified by." It is sufficient that the attendant circumstances, such as treachery and evident premeditation, are stated in ordinary and concise language, enabling a person of common understanding to know the nature of the charge. The Information clearly stated that the accused acted "with treachery and evident premeditation" and "deliberately intent to kill," and attacked the victim "on the back portion of the body," which, when proven, qualifies the killing to murder. The Court emphasized that the specific allegation of the circumstances, not the use of specific legal terms, is what informs the accused and the court.
Main Doctrine
Positive identification of the accused by a credible witness prevails over denial and alibi. Flight from the scene of the crime and from authorities is an indication of guilt. The allegation of treachery in the Information, even if not preceded by the word "qualifying," is sufficient to apprise the accused of the charge for murder if proven.