People v. Villegas
REITERATIONFacts
The Antecedents: On December 18, 1989, at around 11:30 p.m., Lorenzo Marcelo, an eyewitness, was walking home with the victim, Lauro de Guzman. As they approached a lit area, the accused, Marcos Villegas, suddenly emerged from a dark alley, approached the victim from behind, and stabbed him once on the left side of his back with a hunting knife. The accused then fled. The victim was brought to the hospital where he died on December 20, 1989. The autopsy report, conducted by Dr. Dario Gajardo, indicated two stab wounds on the left lumbar region, causing cardio-respiratory arrest due to shock and hemorrhage. Dr. Gajardo also testified that the wound could have been caused by a pointed single-bladed weapon and that the assailant could have been on the victim's left side, with both facing each other. Procedural History: An information for Murder was filed on May 2, 1990. The accused failed to appear for his arrest, and his whereabouts were unknown, leading to the archiving of the case. He was later arrested on August 2, 1993, for violation of R.A. No. 6425. Upon arraignment on September 22, 1993, he pleaded not guilty. The Regional Trial Court (RTC) of Pasig, Branch 164, found the accused guilty beyond reasonable doubt of Murder and sentenced him to reclusion perpetua, with civil indemnity and reimbursement for funeral expenses. The RTC considered the accused's flight as indicative of guilt and appreciated the qualifying circumstance of treachery. The Petition: The accused-appellant sought reversal of the RTC decision, arguing that the trial court erred in giving weight to the eyewitness testimony, which he claimed was doubtful and contradictory, and in holding that treachery attended the killing.
Issue(s)
Whether the trial court erred in giving weight and credence to the testimony of prosecution eyewitness Lorenzo Marcelo. Whether the crime charged was committed with the attendant qualifying circumstance of treachery.
Ruling
The Supreme Court affirmed the decision of the Regional Trial Court, finding the accused-appellant Marcos Villegas guilty beyond reasonable doubt of the crime of Murder. The penalty of reclusion perpetua was upheld.
Ratio Decidendi
On whether the trial court erred in giving weight and credence to the testimony of prosecution eyewitness Lorenzo Marcelo: The Court found no merit in the accused's assertion that the eyewitness testimony of Lorenzo Marcelo was doubtful and contradictory. While there were minor inconsistencies regarding the exact number of stab wounds and the precise angle of attack, these were deemed inconsequential and did not affect the witness's credibility. The Court reiterated the principle that minor inconsistencies may even be badges of veracity. The accused failed to present any improper motive for Marcelo to falsely testify against him, thus the presumption of good faith applied. The trial court's assessment of Marcelo's credibility, having observed his demeanor, was given great weight. On whether the crime charged was committed with the attendant qualifying circumstance of treachery: The Court held that treachery attended the killing, qualifying the crime to Murder. The victim was suddenly and unexpectedly assaulted from behind without warning, precluding any possibility of defense. The Court found that the means, method, or form employed by the accused directly and specially insured the execution of the crime without risk to himself. The argument that the victim might have seen the accused coming from the alley was considered mere speculation, and the suddenness of the attack negated any possibility of the victim being forewarned. The Court also considered the accused's flight as indicative of guilt, noting his disappearance after the filing of the complaint and his subsequent arrest for another offense.
Main Doctrine
Treachery attended the killing, qualifying the crime to murder, when the victim was suddenly, unexpectedly, and without warning assaulted by the accused, precluding the possibility of the victim being forewarned and able to prepare for his defense. Flight of the accused, coupled with the inability to serve the order of arrest, is considered indicative of guilt.