G.R. No. 83358 - Cariday Investment Corp. vs. Court of Appeals

Expedito Alfon was charged with the murder of Tomas S. Alferez, with the incident occurring on February 18, 1993, in Barangay Oring, Municipality of Caramoan, Camarines Sur.
The trial was conducted by the Regional Trial Court (RTC) of San Jose, Camarines Sur (Branch 30) and culminated in a decision on December 18, 1995, convicting Alfon of murder with the penalty of reclusion perpetua.
The decision also imposed civil liabilities which originally included a civil indemnity of ₱50,000, actual damages amounting to ₱24,220, and the payment of costs.

On February 18, 1993, at approximately 2:00 p.m., the prosecution charged that Expedito Alfon, armed with a balisong, followed his victim, Tomas S. Alferez, and suddenly attacked him.
Eyewitness testimony indicated that Alfon approached from behind while the victim was walking and then suddenly stabbed him, inflicting wounds that directly caused the victim’s instantaneous death.
The autopsy conducted by Dr. Minerva Aguirre confirmed two primary stab wounds (one on the right lower part of the victim’s nipple region and a more fatal one on the left lower chest) and an additional incised wound on the victim’s right index finger.

Vicente Eusebio testified that while smoking near a residence, he observed Alfon following the victim and subsequently attacking him from behind by stabbing him twice with the balisong.
Manuel Rayoso provided a corroborative account where he observed Alfon holding the victim’s shoulder and stabbing him at the left lower chest from behind.
Dr. Minerva Aguirre’s post-mortem report supported the prosecution’s narrative, reporting the location and nature of the injuries.
Rodolfo Alferez, the victim’s brother and a key witness for the civil damages, testified regarding the expenses incurred for the victim’s funeral and burial.

During arraignment on July 28, 1993, Expedito Alfon pleaded not guilty, claiming that he was ambushed by the victim and his brother, Rodolfo Alferez.
Alfon’s defense asserted that the victim’s brother, not he, was responsible for the stabbing that resulted in Tomas Alferez’s death.
No other independent evidence was presented to corroborate his version, and the defense rested solely on his denial.

The prosecution’s account was primarily built on the eyewitness testimonies which consistently indicated that the victim was attacked suddenly by an assailant coming from behind.
Minor discrepancies among the testimonies, such as the exact number of stabbing blows (two as per some witnesses and three as surmised by the doctor), were noted but did not undermine the core narrative.
The physical evidence, including the autopsy report, supported the assertion that the fatal wound was inflicted by a sudden, treacherous attack.

On appeal, Alfon raised several errors with the trial court’s findings, particularly regarding the credibility conferred on the eyewitnesses and the application of treachery in the killing.
The trial court’s award of actual damages amounting to ₱24,220 was later modified by the appellate court, which substituted it with ₱25,000 each for temperate and exemplary damages.
Despite the errors alleged by Alfon, the ruling affirmed the conviction, attributing full faith to the consistent eyewitness testimonies and the established chain of evidence.

Whether the trial court erred in giving full faith and credit to the testimonies of the prosecution’s disinterested eyewitnesses.
Whether the minor inconsistencies in the number of stab wounds reported by the witnesses affected the overall credibility of their accounts.

Whether the trial court was correct in finding that the killing was attended by treachery, given that the fatal wound was inflicted on the front of the victim despite assertions that the assailant approached from behind.

Whether the trial court committed an error in not appreciating the defense’s claim that it was actually Rodolfo Alferez who stabbed the victim.
Whether the failure of Expedito Alfon to prove his non-culpability beyond reasonable doubt warranted his conviction.

Whether the trial court erred in not acquitting the accused, given the prosecution’s reliance primarily on eyewitness testimonies and the subsequent discrepancies in accounts.

Whether the trial court improperly awarded actual damages to the victim’s heirs without presenting sufficient corroborative evidence beyond the testimony and an unverified list of expenses.