People v. Fuentes
REITERATIONFacts
The Antecedents: At approximately 10:00 p.m. on May 5, 1996, Rustico Bajar and Manuel Guira were having a drinking spree at the Philtranco Bus Terminal in Tacloban City. At 1:00 a.m. the following day, May 6, 1996, they decided to continue drinking at Paseo de Legaspi. Guira took the first available tricycle, while Bajar followed in the next. As Guira was alighting from his tricycle at Paseo de Legaspi, the appellant, Edwin Fuentes y Carson, suddenly approached and stabbed him in the back and chest. Guira was rushed to the hospital but was pronounced dead on arrival due to fatal wounds in his left lung. Procedural History: Appellant was charged with Murder before the Regional Trial Court (RTC) of Tacloban City, Branch 6. He pleaded not guilty and raised the defenses of denial and alibi, claiming he was sleeping on a pilot boat docked at the Tacloban City pier. The RTC convicted him of Murder, finding that treachery attended the killing and that his alibi was insufficient. Following the ruling in People v. Mateo, the case was referred to the Court of Appeals (CA), which affirmed the RTC decision in toto. The Appeal: The appellant filed the present appeal before the Supreme Court, questioning the credibility of the prosecution's witnesses and the appreciation of treachery. He maintained his innocence based on his alibi and argued that the prosecution failed to prove his guilt beyond reasonable doubt.
Issue(s)
Whether the prosecution established the guilt of the appellant for the crime of murder beyond reasonable doubt, and whether the defense of alibi and denial can prevail over the positive identification of the accused. Whether the qualifying circumstance of treachery was correctly appreciated by the lower courts. Whether the defense of alibi and denial can prevail over the positive identification of the accused. Whether the award of damages (civil indemnity, moral, and exemplary) is consistent with current jurisprudence.
Ruling
The appeal is DENIED. The September 27, 2006 decision of the Court of Appeals in CA-G.R. CEB-CR-H.C. No. 00297 is AFFIRMED with MODIFICATION. Appellant Edwin Fuentes y Carson is found guilty of Murder and sentenced to suffer the penalty of reclusion perpetua without eligibility for parole. He is further ordered to pay the heirs of Manuel Guira P75,000 in civil indemnity, P50,000 in moral damages, and P25,000 in exemplary damages.
Ratio Decidendi
On Issue 1: The Court held that the positive identification of the appellant by the prosecution witnesses as the person who stabbed the victim prevails over the defense of denial and alibi. Alibi is considered an inherently weak defense and can only be given weight if it is shown that it was physically impossible for the accused to be at the scene of the crime. In this case, the pier where the appellant claimed to be was only approximately one kilometer away from Paseo de Legaspi, the crime scene. Therefore, it was not physically impossible for him to have committed the crime and returned to the boat. The witnesses categorically pointed to the appellant, and their testimonies were found credible by both the trial and appellate courts. On Issue 2: Treachery was correctly appreciated because the attack was characterized by suddenness and the victim's lack of opportunity to defend himself. The victim was in the process of alighting from a tricycle and had no inkling that he would be assaulted, which effectively deprived him of any chance to retaliate or escape. This deliberate use of a sudden attack ensures the execution of the killing without risk to the offender. The Court found no reason to disturb the findings of the lower courts that the attack was carried out treacherously. Consequently, the crime is properly classified as Murder under Article 248 of the Revised Penal Code (RPC). On Issue 3: The Court held that the positive identification of the appellant by the prosecution witnesses as the person who stabbed the victim prevails over the defense of denial and alibi. Alibi is considered an inherently weak defense and can only be given weight if it is shown that it was physically impossible for the accused to be at the scene of the crime. In this case, the pier where the appellant claimed to be was only approximately one kilometer away from Paseo de Legaspi, the crime scene. Therefore, it was not physically impossible for him to have committed the crime and returned to the boat. The witnesses categorically pointed to the appellant, and their testimonies were found credible by both the trial and appellate courts. On Issue 4: The Court modified the award of damages to conform with current jurisprudence. Civil indemnity was increased from P50,000 to P75,000, as this award is mandatory upon the commission of the crime of murder without need of further proof. The grant of P50,000 in moral damages was sustained due to the violent nature of the death and the resulting grief of the victim's family. Furthermore, the Court awarded P25,000 in exemplary damages pursuant to Article 2230 of the Civil Code because the crime was committed with the qualifying aggravating circumstance of treachery. Under Republic Act (RA) No. 9346, the appellant is not eligible for parole while serving the sentence of reclusion perpetua.
Main Doctrine
The qualifying circumstance of treachery (alevosia) is present when the attack is sudden and unexpected, depriving the victim of any real chance to defend himself and thereby ensuring the execution of the crime without risk to the offender. In evidentiary law, a positive identification made by a witness who has no ill motive to testify falsely against the accused is given full faith and credit. For the defense of alibi to prosper, the accused must demonstrate not only that he was elsewhere at the time of the crime but also that it was physically impossible for him to be at the scene of the crime at the time of its commission.