People v. Corpuz
REITERATIONFacts
The Antecedents: Manuel Corpuz (Manuel) was charged with two (2) counts of murder for the deaths of Romana P. Arcular (Romana) and Leonila C. Risto (Leonila). The Informations alleged that Manuel, with deliberate intent to kill, treachery, and abuse of superior strength, attacked and hacked the victims with a bolo, causing fatal wounds. Procedural History: The Regional Trial Court (RTC) of Abuyog, Leyte, Branch 10, found Manuel guilty beyond reasonable doubt of two (2) counts of murder and sentenced him to suffer the penalty of reclusion perpetua for each count, with monetary awards for civil indemnity, moral damages, and exemplary damages. The Court of Appeals (CA) affirmed the RTC decision with modification, increasing exemplary damages and awarding temperate damages. Manuel appealed to the Supreme Court. The Petition: Manuel argued that his conviction was based mainly on the testimony of Leonilo, a prosecution eyewitness, whom he claimed was not credible due to contradictions with the police blotter. He contended that the prosecution failed to prove his guilt beyond reasonable doubt.
Issue(s)
Whether the trial and appellate courts erred in convicting accused-appellant Manuel Corpuz for the deaths of Romana Arcular and Leonila Histo despite the prosecution's failure to prove his guilt beyond reasonable doubt. Whether the aggravating circumstance of treachery attended the commission of the crimes.
Ruling
The appeal lacks merit. The Supreme Court affirmed the conviction of Manuel Corpuz for two (2) counts of murder, sentencing him to suffer the penalty of reclusion perpetua for each count. The Court ordered him to pay the respective heirs of Romana P. Arcular and Leonila C. Histo specific amounts as civil indemnity, moral damages, exemplary damages, and temperate damages, with legal interest.
Ratio Decidendi
On the issue of guilt beyond reasonable doubt and the credibility of the eyewitness: The Court held that entries in a police blotter are not evidence of the truth of the facts stated therein but merely of the fact that the entries were made. Affidavits executed before the police or entries in police blotters cannot prevail over positive testimony given in open court. The Court found Leonilo's testimony credible, noting that he positively identified Manuel, whom he had known for years. Leonilo also provided a sufficient explanation for any apparent inconsistencies with the police blotter, stating that he merely reported what he witnessed and that the accuracy of the police recording was beyond his control. The Court reiterated that alibi is an inherently weak defense that cannot prevail over positive and credible eyewitness testimony. Furthermore, Manuel's alibi was weakened by his wife's testimony placing him only 200 meters away from the crime scene, which did not establish the required physical impossibility for the defense to prosper. On the presence of treachery as a qualifying circumstance: The Court disagreed with the appellate court's finding of treachery. It reiterated that for treachery to be appreciated, two conditions must be met: (1) the employment of means of execution that gives the victim no opportunity to defend himself or retaliate, and (2) the means of execution was deliberately or consciously adopted. The Court found that mere suddenness of an attack is insufficient to constitute treachery if it does not appear that the aggressor consciously adopted the mode of attack to facilitate the killing without risk to himself. In this case, the prosecution failed to present evidence showing that Manuel consciously adopted his mode of attack without risk to himself, thus, treachery could not be appreciated.
Main Doctrine
The Court affirmed the conviction for murder, holding that the eyewitness testimony was credible despite inconsistencies with the police blotter, and that the aggravating circumstance of abuse of superior strength was present due to the victims' age and defenselessness against an armed assailant. Treachery was not appreciated due to lack of evidence of conscious adoption of a mode of attack to ensure execution without risk.