G.R. No. 186412 ; September 7, 2011
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. ORLITO VILLACORTA, Accused-Appellant.

FACTS

On June 21, 2002, an Information was filed charging Orlito Villacorta with Murder for stabbing Danilo Cruz with a sharpened bamboo stick on January 23, 2002, in Navotas, Metro Manila. The accused pleaded not guilty. The prosecution presented Cristina Mendeja, an eyewitness who owned a sari-sari store where both the victim and the accused were regular customers. She testified that at around 2:00 a.m., while Cruz was ordering bread, Villacorta suddenly appeared and, without a word, stabbed Cruz on the left side of his body with a sharpened bamboo stick, which broke and was left embedded. Villacorta immediately fled, and Mendeja gave chase but failed to catch him. Cruz was brought to Tondo Medical Center and later to San Lazaro Hospital, where he died on February 15, 2002. Dr. Domingo Belandres, Jr., testified based on Cruz’s medical chart that the cause of death was tetanus infection secondary to the stab wound. The defense presented Villacorta, who denied the stabbing and claimed that on the early morning of January 21, 2002, he only boxed Cruz after Cruz put an arm around his shoulder, and he was unaware Cruz was hurt until his arrest on July 31, 2002. The Regional Trial Court found Villacorta guilty of Murder qualified by treachery and sentenced him to reclusion perpetua and to pay civil indemnity. The Court of Appeals affirmed the RTC decision in toto.

ISSUE

1. Whether the prosecution proved the guilt of the accused beyond reasonable doubt.
2. Whether the qualifying circumstance of treachery was correctly appreciated.
3. Assuming a crime was committed, whether the accused should only be liable for slight physical injuries.

RULING

The Supreme Court denied the appeal and affirmed the conviction. On the first issue, the Court upheld the credibility of eyewitness Cristina Mendeja, noting that the trial court’s assessment of witness credibility is accorded great respect. It rejected Villacorta’s arguments regarding inconsistencies in Mendeja’s testimony (e.g., her reaction to chase the assailant instead of shouting, the opportunity to identify him given the store’s lighting and her familiarity with both men, and the handling of the bamboo stick) as insufficient to cast doubt on her positive identification. The Court found her testimony credible and consistent. On the second issue, the Court affirmed the presence of treachery. The attack was sudden and unexpected, executed in a manner that deprived the victim of any chance to defend himself, as Villacorta stabbed Cruz without warning while Cruz was ordering bread. On the third issue, the Court held Villacorta liable for Murder, not slight physical injuries. The direct and proximate cause of Cruz’s death was the stab wound inflicted by Villacorta, which led to a tetanus infection. The Court cited the doctrine that the offender is liable for all the consequences of his felonious act, and the fact that the victim died more than three weeks later due to infection does not negate the causal link between the stabbing and the death. The penalty of reclusion perpetua and the award of civil indemnity were affirmed.