G.R. No. 123456

PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee,
vs.
JUAN DELA CRUZ, Accused-Appellant.

PROMULGATED: [Date]

D E C I S I O N

LEONEN, J.:

Before this Court is an appeal from the Decision of the Court of Appeals which affirmed with modification the Decision of the Regional Trial Court finding accused-appellant Juan Dela Cruz guilty beyond reasonable doubt of the crime of Murder, qualified by treachery, and sentencing him to suffer the penalty of reclusion perpetua.

The factual and procedural antecedents are as follows:

The prosecution alleged that on the evening of January 15, 2010, in Barangay San Isidro, Makati City, the victim, Pedro Santos, was having a drinking session with friends. At around 10:00 p.m., accused-appellant Juan Dela Cruz suddenly appeared, uttered “Papatayin kita!” and without any warning or provocation, stabbed Santos multiple times with a kitchen knife. Santos was rushed to the hospital but was pronounced dead on arrival. The cause of death was multiple stab wounds, with the fatal wound penetrating the heart.

The defense presented a different version. Accused-appellant claimed he was at home, several kilometers away, at the time of the incident. He alleged that the prosecution witnesses, who were friends of the victim, conspired to frame him due to a long-standing land dispute between their families.

The Regional Trial Court gave credence to the testimonies of the prosecution witnesses, who positively identified accused-appellant as the assailant. The court found that the attack was sudden and unexpected, depriving the victim of any chance to defend himself, thereby qualifying the killing to Murder through treachery (alevosia). It convicted accused-appellant of Murder and sentenced him to reclusion perpetua. It also ordered him to pay civil indemnity, moral damages, and exemplary damages to the heirs of the victim.

On appeal, the Court of Appeals affirmed the conviction but modified the damages awarded, increasing the amounts in accordance with prevailing jurisprudence.

In his appeal before this Court, accused-appellant raises the following errors:

1. THE COURT A QUO GRAVELY ERRED IN GIVING FULL WEIGHT AND CREDENCE TO THE INCONSISTENT AND INCREDIBLE TESTIMONIES OF THE PROSECUTION WITNESSES.
2. THE COURT A QUO GRAVELY ERRED IN CONVICTING HIM OF MURDER DESPITE THE PROSECUTION’S FAILURE TO PROVE THE QUALIFYING CIRCUMSTANCE OF TREACHERY BEYOND REASONABLE DOUBT.
3. THE COURT A QUO GRAVELY ERRED IN NOT APPRECIATING HIS DEFENSE OF ALIBI.

The Court’s Ruling

The appeal is without merit. The conviction is affirmed with modifications to the awards of damages.

I. Credibility of Witnesses

The trial court’s assessment of the credibility of witnesses is entitled to great weight and respect, as it had the unique opportunity to observe their demeanor, conduct, and attitude on the witness stand. Absent any showing that it overlooked, misunderstood, or misapplied facts or circumstances of weight which would alter the outcome of the case, its findings are binding on this Court.

Accused-appellant’s claim of inconsistencies pertains to minor details, such as the exact number of seconds the incident lasted or the precise distance of the witnesses from the scene. These minor inconsistencies do not detract from the witnesses’ positive identification of accused-appellant as the perpetrator. In fact, they may even enhance credibility, as they indicate that the testimonies were not rehearsed.

All three prosecution witnesses gave a clear, consistent, and categorical account of how accused-appellant suddenly attacked the unsuspecting victim. Their positive identification prevails over accused-appellant’s denial and alibi.

II. Proof of Treachery

For treachery to qualify a killing to Murder, two conditions must concur: (1) the employment of means, methods, or forms of execution that ensure the safety of the offender from any defensive or retaliatory act on the part of the victim; and (2) the deliberate and conscious adoption of such means.

The evidence convincingly establishes these elements. The victim was seated, drinking with friends, and was completely unaware of any impending danger. Accused-appellant approached from behind and launched a sudden and violent attack with a deadly weapon, giving the victim no opportunity to flee or fight back. The mode of attack was deliberately adopted to ensure the execution of the crime without risk to accused-appellant. Hence, the qualifying circumstance of treachery was proven beyond reasonable doubt.

III. Defense of Alibi

Alibi is inherently a weak defense. For it to prosper, the accused must prove not only that he was somewhere else when the crime was committed but also that it was physically impossible for him to have been at the scene of the crime.

Accused-appellant claimed he was at his home. However, he failed to prove that the distance between his home and the crime scene made it physically impossible for him to be present at the locus criminis. His own testimony revealed that the distance could be traversed by a 30-minute jeepney ride. This does not constitute physical impossibility. His alibi must therefore fail, especially in light of the positive identification by credible witnesses.

IV. Damages

In line with current jurisprudence in Murder cases, the awards for damages are modified as follows:

1. Civil Indemnity: ₱75,000.00
2. Moral Damages: ₱75,000.00
3. Exemplary Damages: ₱75,000.00

Exemplary damages are warranted due to the presence of the qualifying aggravating circumstance of treachery.

Furthermore, in accordance with People v. Jugueta, and to reflect the current policy, temperate damages in the amount of ₱50,000.00 are awarded in lieu of actual damages, as the prosecution proved that the heirs incurred funeral and burial expenses but did not provide receipts for the full amount.

All monetary awards shall earn legal interest at the rate of six percent (6%) per annum from the date of finality of this judgment until fully paid.

WHEREFORE, the Decision of the Court of Appeals is AFFIRMED with MODIFICATION. Accused-appellant JUAN DELA CRUZ is found GUILTY BEYOND REASONABLE DOUBT of the crime of MURDER, defined and penalized under Article 248 of the Revised Penal Code, and is sentenced to suffer the penalty of RECLUSION PERPETUA, without eligibility for parole.

He is ordered to pay the heirs of the victim, Pedro Santos, the following amounts:
1. Civil Indemnity ₱75,000.00;
2. Moral Damages ₱75,000.00;
3. Exemplary Damages ₱75,000.00; and
4. Temperate Damages ₱50,000.00.

All monetary awards shall earn legal interest at the rate of six percent (6%) per annum from the finality of this judgment until fully paid.

SO ORDERED.

Gesmundo, C.J., (Chairperson), Caguioa, Lazaro-Javier, and J. Lopez, JJ., concur.