People v. Abaño
REITERATIONFacts
The Antecedents: On October 5, 2005, Charlie Abaño y Cañares was charged with murder for allegedly hacking Cesar Cabase y San Joaquin to death on October 3, 2005, around 10:00 p.m., in Brgy. Del Socorro, Minalabac, Camarines Sur. The Information alleged that the killing was done with intent to kill, treachery, and evident premeditation. Procedural History: The victim's wife, Richelda Madera Cabase, testified as an eyewitness. She stated that the victim was asleep in their hut when the appellant suddenly entered, shone a flashlight on the victim, and began hacking him with a bolo. Richelda retreated out of fear. Medico-legal findings confirmed that multiple hack wounds and skull fractures caused the victim's death. The appellant interposed the defense of alibi, claiming he was asleep at a nearby farm. The RTC convicted the appellant of murder, appreciating treachery as a qualifying circumstance but disregarding evident premeditation. The RTC sentenced him to reclusion perpetua and awarded civil indemnity, moral damages, and temperate damages. The Court of Appeals (CA) affirmed the conviction but deleted the temperate damages, awarding only actual damages proven by receipts. The CA modified the award to ₱5,000.00 as actual damages. The Petition: The appellant appealed his conviction to the Supreme Court.
Issue(s)
Whether the guilt of the appellant for the crime of murder was proven beyond reasonable doubt. Whether treachery attended the commission of the crime. Whether the awarded damages were proper.
Ruling
The Supreme Court affirmed the appellant's guilt for murder, upholding the findings of the RTC and CA. The Court modified the awarded damages, granting temperate damages and exemplary damages.
Ratio Decidendi
On the guilt of the appellant for the crime of murder: The Court found no reason to disturb the findings of the RTC and CA. The eyewitness account of the victim's wife was deemed credible, consistent, and without any imputed ill motive. Her testimony was corroborated by the physical evidence. The appellant's defense of alibi was unconvincing, as he was only 300 meters away from the scene of the crime, making it physically possible for him to have been present. The Court reiterated that the defense of alibi must be supported by convincing evidence and cannot prevail over the positive identification by a credible eyewitness. The straightforward account of the witness, consistent with the physical evidence, established the appellant's culpability beyond reasonable doubt. On whether treachery attended the commission of the crime: The Court affirmed the RTC's appreciation of treachery as a qualifying circumstance. The victim was asleep at the time of the assault, rendering him completely defenseless and unable to offer any resistance or warning. The manner of attack, wherein the appellant suddenly barged into the room and immediately began hacking the sleeping victim, ensured that the victim could not have defended himself. This mode of attack, which deliberately deprived the victim of any opportunity to defend himself, squarely fits the definition of treachery. The presence of treachery qualified the killing to murder under Article 248 of the Revised Penal Code. On the awarded damages: The Court modified the damages awarded by the CA. While affirming the civil indemnity of ₱50,000.00 and moral damages of ₱50,000.00, the Court found that temperate damages should have been awarded in lieu of actual damages because the receipted expenses were less than ₱25,000.00. The Court awarded ₱25,000.00 as temperate damages. Furthermore, due to the presence of the qualifying circumstance of treachery, the Court awarded exemplary damages in the amount of ₱30,000.00, consistent with established jurisprudence.
Main Doctrine
The Court affirmed the conviction for murder, holding that treachery qualified the killing as murder because the victim was asleep and defenseless. The Court also modified the award of damages, granting temperate damages in lieu of actual damages when receipts were insufficient and awarding exemplary damages due to the presence of treachery.