People v. Dizon
REITERATIONFacts
The Antecedents: On December 25, 2001, the lifeless body of Jeto Santos was found floating in a creek. Eyewitness accounts identified Rodel Dizon, appellant Isaias Dizon, and Virgilio Pascua as the last persons seen with the victim. Consequently, the three were arrested and charged. Procedural History: The Provincial Prosecutor found probable cause to charge only appellant Isaias Dizon with Murder. The Information alleged that on December 24, 2001, the appellant, with intent to kill and with treachery, attacked the victim by hitting him thrice in the head with stones, causing his death. The Regional Trial Court (RTC) convicted the appellant of Murder, sentencing him to suffer reclusion perpetua and to pay civil indemnity, moral damages, actual expenses, and temperate damages. The Court of Appeals affirmed the RTC decision in toto. The Petition: The appellant appealed to the Court of Appeals, faulting the trial court for finding him guilty beyond reasonable doubt and for appreciating the qualifying circumstance of treachery. The Court of Appeals upheld the trial court's findings.
Issue(s)
Whether the appellant was guilty beyond reasonable doubt of Murder, and whether treachery attended the killing. On the civil aspect of the case.
Ruling
The Court affirmed the decision of the Court of Appeals, with modifications to the civil aspect of the case. The award of civil indemnity was reduced, the award of temperate damages was deleted, and exemplary damages were awarded.
Ratio Decidendi
On the guilt of the appellant and the presence of treachery: The Court held that treachery was present. The appellate court found that the act of hitting the victim again with a stone while he was already sprawled on the ground, with his hands spread out, insured that the victim had no opportunity to defend or retaliate. The deliberate throwing of stones, of significant sizes, for a number of times, demonstrated the appellant's chosen manner of execution. The Court reiterated that treachery can exist even if the attack is frontal, provided it is sudden and unexpected, giving the victim no opportunity to defend himself. The appellant's picking up of a stone and crashing it upon the victim's head was sudden, and the attack was directed to the head, indicating an intent to render the victim unconscious or kill him instantly, thus rendering him defenseless. The gravity of the head wounds, which exposed brain tissues, confirmed this intent. The eyewitness identification by Rodel, the appellant's grandson, was accorded significant weight, considering the natural hesitancy of people to get involved in criminal cases, especially when a relative is involved. The appellant's alibi, corroborated by his wife, was found unmeritorious as their house was only 50 meters away from the bar, making his presence at the crime scene not impossible. Therefore, the appellant was found guilty beyond reasonable doubt of Murder, with treachery as a qualifying circumstance. On the civil aspect: The Court modified the awards. In line with prevailing jurisprudence, the award of civil indemnity was reduced from P75,000.00 to P50,000.00. The award of temperate damages was deleted because actual damages had already been awarded. Exemplary damages in the amount of P25,000.00 were awarded, as treachery was present as an aggravating circumstance.
Main Doctrine
Treachery can exist even if the attack is frontal, if it is sudden and unexpected, giving the victim no opportunity to defend himself. The award of temperate damages is deleted when actual damages have already been awarded. Exemplary damages may be awarded when an aggravating circumstance is present.