GR No. 123456, January 30, 2024
People of the Philippines v. Juan Dela Cruz

FACTS

Accused-appellant Juan Dela Cruz was charged with the crime of Murder for the fatal stabbing of Pedro Santos. The prosecution presented an eyewitness, Maria Reyes, who testified that she saw Dela Cruz, whom she knew personally, stab the victim from behind during a street altercation. The defense interposed alibi, claiming Dela Cruz was in a different city at the time of the incident. The Regional Trial Court convicted Dela Cruz of Murder, qualified by treachery, and sentenced him to reclusion perpetua. The Court of Appeals affirmed the conviction. Dela Cruz now appeals before the Supreme Court, arguing that the prosecution failed to prove his guilt beyond reasonable doubt and that the qualifying circumstance of treachery was not sufficiently established.

ISSUE

1. Whether the guilt of accused-appellant Juan Dela Cruz for the crime of Murder was proven beyond reasonable doubt.
2. Whether the qualifying circumstance of treachery was duly established to justify the conviction for Murder.

RULING

1. The guilt of the accused for Homicide is proven beyond reasonable doubt, but not for Murder.
The Court finds the positive identification by eyewitness Maria Reyes, who had no motive to falsely testify, to be clear, consistent, and credible. Her testimony prevails over the weak defense of alibi, which was not physically impossible. Thus, the accused’s presence and participation in the fatal stabbing are established beyond moral certainty.

2. No, the qualifying circumstance of treachery was not proven.
The prosecution failed to establish how the attack was commenced. The eyewitness only saw the actual stabbing from behind but did not witness the inception of the altercation. Treachery requires that the means of execution were deliberately adopted without giving the victim any opportunity to defend or retaliate. When the manner of attack is not clearly shown, as in this case, treachery cannot be appreciated. The killing is therefore classified as Homicide, not Murder, under Article 249 of the Revised Penal Code.

DISPOSITIVE PORTION:
WHEREFORE, the Decision of the Court of Appeals is MODIFIED. Accused-appellant JUAN DELA CRUZ is found GUILTY of HOMICIDE and is sentenced to suffer the indeterminate penalty of eight (8) years and one (1) day of *prision mayor* as minimum, to fourteen (14) years, eight (8) months and one (1) day of *reclusion temporal* as maximum. He is ordered to pay the heirs of Pedro Santos civil indemnity, moral damages, and temperate damages, all with legal interest until fully paid.