People v. Del Rosario
REITERATIONFacts
The Antecedents: On December 20, 2004, at approximately 9:00 p.m., Edwin Gelua was having a drinking spree with Salvador and Samson Gepiga at his home. Edwin went outside to urinate. Angelita Gelua, Edwin's wife, was by the main door when appellant Alvin del Rosario suddenly appeared and stabbed Edwin with a machete. Angelita brought Edwin to the Bulan Municipal Hospital, then to Sorsogon Provincial Hospital, where he died. Procedural History: The Information charged appellant with murder. The prosecution presented four witnesses: Angelita Gelua, Dr. Andrew A. de Castro, Salvador Gelua, and Ruel Garlan. Dr. De Castro testified that the cause of death was cardio-respiratory arrest due to a stab wound and hypovolemic shock, noting the stab wound was on the right upper quadrant of the abdomen, perforating the stomach and duodenum, and lacerating the middle colic artery and mesenteric vessels. He opined the victim was likely face-to-face with the assailant or the assailant was behind the victim. Salvador corroborated Angelita's testimony, stating he heard Edwin shouting for help and saw appellant holding a knife before fleeing. Ruel testified that appellant initially denied the stabbing but later admitted it and surrendered the weapon, after which Ruel brought appellant to the police station. Appellant invoked his right to remain silent and presented no evidence. The Regional Trial Court (RTC) of Bulan, Sorsogon, found appellant guilty of murder and sentenced him to reclusion perpetua, with indemnification for damages. The Court of Appeals (CA) affirmed the RTC decision in toto. The Petition: Appellant appealed to the Supreme Court, arguing that the trial court erred in giving undue weight to the testimonies of Angelita and Salvador, in convicting him of murder due to insufficient proof, and in admitting his alleged admission and surrender of the weapon without counsel.
Issue(s)
Whether the prosecution proved appellant's guilt beyond reasonable doubt. Whether treachery attended the killing of Edwin Gelua. Whether the trial court erred in admitting the alleged admission and surrender of the weapon without the assistance of counsel.
Ruling
The Supreme Court dismissed the appeal, affirmed the decision of the Court of Appeals with modifications, and found appellant Alvin del Rosario guilty beyond reasonable doubt of murder. He was sentenced to reclusion perpetua and ordered to pay civil indemnity, moral damages, temperate damages, and exemplary damages to the heirs of Edwin Gelua.
Ratio Decidendi
On the issue of guilt beyond reasonable doubt: The Court held that the positive identification of the appellant by the prosecution witnesses, Angelita and Salvador, who were consistent and had no proven improper motive, prevailed over the appellant's bare denial. The Court reiterated the rule that the findings of the trial court on the credibility of witnesses are entitled to great weight and respect, especially when affirmed by the Court of Appeals, and will not be disturbed absent any showing of overlooked facts or circumstances that could affect the outcome. The alleged improper motive of Angelita and Salvador was deemed speculative, as it is unnatural for relatives seeking justice to impute the crime to an innocent person. The Court cited People v. Daraman and People v. Lovedorial in support of these principles. The appellant's failure to present evidence to support his defense further weakened his position against the positive identification. Regarding the penalty and damages, the Court upheld the penalty of reclusion perpetua for murder, as provided under Article 248 of the Revised Penal Code, as amended by RA 7659, in the absence of aggravating or mitigating circumstances. Regarding damages, the Court sustained the awards of ₱50,000.00 as civil indemnity and ₱50,000.00 as moral damages, as these require no proof other than the fact of death and the accused's responsibility. The Court modified the award of actual damages, stating that when proven actual damages are less than ₱25,000.00, temperate damages of ₱25,000.00 are proper in lieu thereof, citing People v. Panganiban. Thus, ₱25,000.00 as temperate damages was awarded. Finally, the Court included an award of ₱30,000.00 as exemplary damages, as an aggravating circumstance should entitle the offended party to such an award under Article 2230 of the Civil Code. On the issue of treachery: The Court affirmed the finding of treachery, defining it as a sudden and unexpected attack on an unsuspecting victim, depriving him of any real chance to defend himself and ensuring the commission of the crime without risk to the aggressor. The Court found that the attack on Edwin, who was urinating and unarmed, was sudden, unprovoked, unexpected, and deliberate, leaving him no opportunity to defend himself or retaliate. This satisfied the elements of treachery, qualifying the crime to murder. The Court cited alevosia as the essence of treachery. On the issue of the admissibility of the alleged admission and surrender of the weapon: The Court found the argument specious because appellant did not raise any objection to Ruel Garlan's testimony regarding the alleged admission and surrender of the weapon during the trial. The Court emphasized the rule that objections to the admissibility of evidence must be made at the proper time, and failure to do so constitutes a waiver. Therefore, the RTC could not be faulted for admitting the testimony. Furthermore, the Court noted that the conviction was not based on this alleged admission but primarily on the positive testimonies of Angelita and Salvador, rendering the circumstances surrounding the admission inconsequential.
Main Doctrine
The positive identification of the accused by credible witnesses, consistent and without ill motive, prevails over a bare denial, especially when the accused opts not to present evidence to support his defense. The admissibility of evidence, if not objected to at the proper time, is deemed waived. In murder cases, treachery is established by the sudden and unexpected attack on an unsuspecting victim, depriving him of any real chance to defend himself.