G.R. No. 181843 - Cirera y Ustelo vs. People

Miguel Cirera y Ustelo was charged in two informations for frustrated murder for an incident that occurred on April 20, 2000, in Quezon City.
The accusations involve two counts where petitioner allegedly attacked Gerardo Naval and Romeo Austria with a sharp-bladed weapon.
Despite the inflicted stab wounds being potentially fatal, timely and effective medical treatment prevented the deaths of the complainants.

According to the prosecution, petitioner's actions were characterized by intent to kill with evident premeditation and by means of treachery.
Facts presented include:

Petitioner arrived at the scene asking money for liquor, initiating an altercation.
Testimonies from the complainants—Romeo Austria and Gerardo Naval—describe a sequence of aggressive encounters in which petitioner allegedly chased, stabbed, and nearly fatally wounded them.

The complainants testified to being attacked suddenly, with one witness (Austria) noting that petitioner was seen holding a knife and attempting further stabbings.

Described being at a wake when petitioner approached him, asking for money.
Recounted that after a verbal dispute, he felt stabbed and later noticed petitioner chasing Gerardo Naval.

Recounted an exchange of words with petitioner followed by a physical assault in which he was struck on the back.
Claimed an attempt by petitioner to stab him again prompted his own defensive actions.

Testimonies by Dr. Carlos Angeles and Dr. Arnold Angeles corroborated the severity of the stab wounds.
Medical reports indicated that without immediate surgical intervention, the injuries could have been fatal.

At arraignment, petitioner pleaded not guilty to the charges.
The Regional Trial Court found petitioner guilty beyond reasonable doubt of two counts of frustrated murder and imposed an indeterminate penalty (minimum of six years and one day of prision mayor and maximum of 17 years and four months of reclusion temporal per count).
The Court of Appeals affirmed the decision of the trial court despite petitioner's arguments regarding inconsistencies in the prosecution’s witnesses’ testimonies.
Petitioner raised questions regarding the sufficiency of evidence, focusing on alleged inconsistencies in witness accounts as well as issues regarding the recovery and identification of the weapon.

The lower courts noted that although the evidence of premeditation was not entirely uniform, there was sufficient demonstration of treachery based on the delay in the complainants’ realization of the attack.
Petitioner argued that the elements of treachery—namely, the deliberate use of means to ensure safety from defensive retaliation—were not clearly established.
The prosecution contended that the chain of circumstantial evidence, including witness identifications and the circumstances of the incident, established petitioner's guilt.

Whether the evidence presented, particularly the circumstantial elements and witness identifications, proved petitioner's guilt beyond reasonable doubt.
Whether the alleged inconsistencies in the testimonies of Republic witnesses affected the overall credibility and the factual determination of the case.

Whether petitioner’s method of attack, though sudden and unexpected, met the legal requisites of treachery.
Whether the failure to clearly demonstrate deliberate measures taken to insulate petitioner from defensive retaliation negates the qualification of the offense as frustrated murder instead of frustrated homicide.

Whether the sentencing, based on the convictions for frustrated murder, was justified given the particular circumstances of the case, including the impulsive nature of the altercation.
Whether the modification of penalties and damages awarded should have been reconsidered in light of the evidence regarding treachery and intent.