Facts:

In the case of People of the Philippines v. Adriano Arca, the appellant, Adriano Arca, was charged with the murder of Rommel Godornez, under Criminal Case No. 10866, in the Regional Trial Court of Borongan, Eastern Samar. The events leading to the charge occurred on July 16, 1997, at approximately 9:00 AM in Barangay Maypangdan, Borongan. The Information filed on July 17, 1997, alleged that Arca, with evident premeditation and treachery, stabbed the victim utilizing a sharp weapon known as a "dipang." The stabbing resulted in fatal injuries, leading to Godornez's death. During the trial, several witnesses, including neighbors and law enforcement officers, testified against Arca. The prosecution's key witnesses, Donald Arnulfo and Susan Agda, reported seeing Arca attack Godornez from behind as he left his home to go to school.

In defense, Arca, along with his brother Roberto, claimed that another relative, Romeo Arca, was responsible for the stabbing. The trial

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Facts:

Incident Overview

• On July 16, 1997, at about 9:00 A.M., a stabbing occurred at Barangay Maypangdan, Borongan, Eastern Samar during the barrio fiesta.
• The victim, Rommel Godornez, was fatally wounded by stab wounds inflicted by the accused, Adriano Arca, using a sharp pointed weapon locally known as a “depang” (also spelled “dipang”).

Prosecution’s Account and Evidence

• The Regional Trial Court of Borongan, Eastern Samar, convicted Adriano Arca of murder based on detailed eyewitness testimonies and forensic evidence.
• Witness Donald Arnulfo Alido testified that he observed Arca coming from a house behind the victim’s, attacking the victim from the back, with blows directed at the right arm and breast.
• Police Officer Reynaldo Afable testified that upon being informed by a barangay tanod (and later Kagawad Ipe), he pursued Arca who was seen holding a bloodied bolo, prompting Arca to surrender.
• Witness Susan Agda, the victim’s aunt, confirmed that she saw Arca from the back holding a bolo and observed him inflict the fatal blow as her nephew was about to be attacked.
• Medical Evidence
• The post-mortem report prepared by Dr. Edgardo E. Juaban noted a stab wound on the right anterior chest with a clean cut that penetrated the lung and pulmonary blood vessel, causing massive hemothorax and cardio-pulmonary arrest due to hypovolemic shock.
• A second incised wound on the left forearm was also noted, though it was less consequential relative to the fatal chest wound.

Testimonies and Defense

• Prosecution Rebuttal Witnesses
• Sofronio Obina testified that despite a claim by the defense that Romeo Arca might have been the assailant, he clearly saw the accused in possession of the bolo, which he later saw being quickly re-sheathed and discarded.
• Romeo Arca himself testified as a rebuttal witness, contradicting the defense’s version by placing Adriano Arca at the scene holding the weapon.
• Defense Witnesses and Testimonies
• Roberto Arca, the 11-year-old brother of the accused, testified that on the morning of the incident, he and his brother encountered their cousin, Romeo Arca, during an incident where it was allegedly Romeo who stabbed the victim.
• The accused, Adriano Arca, presented his own testimony confirming Roberto’s account partially, while denying acquaintance with the prosecution witnesses and asserting that his state of inebriation and a physical assault by his cousin led to the confusion over events.
• Other Circumstantial Testimonies
• Discrepancies arose regarding the movement and presence of passengers during the trip to Barangay Maypangdan, as evidenced during cross-examination on the alleged journey in a motorized tricycle and the subsequent arrival at the uncle’s house.
• The testimonies revealed inconsistencies in recounting the precise actions immediately before and after the stabbing, thereby spotlighting contrasting accounts between the defense and prosecution.

Trial Court Ruling and Sentencing

• The trial court found Adriano Arca guilty beyond reasonable doubt of murder under Article 248 of the Revised Penal Code, with treachery as an aggravating circumstance.
• Originally sentenced to death, Arca was also ordered to indemnify the victim’s heirs with an amount of P50,000 and to pay the costs.
• The case was subjected to automatic review by the appellate court, wherein issues of treachery, witness credibility, and mitigating circumstances such as voluntary surrender were thoroughly examined.

Evidentiary and Contextual Background

• The prosecution’s evidence was supported by consistent accounts from eyewitnesses (Alido, Afable, Agda) and was corroborated by the postmortem findings.
• The defense’s reliance on Roberto Arca’s testimony and the subsequent attempt to shift blame to Romeo Arca were critically examined and found unconvincing in light of the established testimonies and physical evidence.
• The circumstances of the incident, including Arca’s state of inebriation and voluntary surrender (including giving up the weapon), were significant factors in the appellate court’s analysis of the proper sentence.

Issue:

Sufficiency of Evidence

• Whether the evidence on record is sufficient to establish beyond reasonable doubt that Adriano Arca committed the murder of Rommel Godornez.
• The credibility and consistency of the eyewitness testimonies vis-à-vis the contradictory defense accounts.

Qualification of the Offense by Treachery

• Whether the trial court correctly identified treachery as an aggravating circumstance in the commission of the murder.
• Whether the nature of the wounds and the manner of the attack, despite being frontal, nonetheless satisfy the requisites of treachery.

Credibility and Weight of Witnesses

• Whether the trial court erred in giving greater weight to the positive declarations of the prosecution witnesses against the inconsistent and contradictory testimonies of the defense witnesses.
• Whether the defense’s claims about the witnesses’ inconsistent accounts have merit in undermining the prosecution’s case.

Applicability of Mitigating Circumstance

• Whether voluntary surrender, evidenced by the accused’s giving up of the bolo and his immediate surrender to police, should be considered as a mitigating circumstance to reduce the imposed penalty.
• The impact of such mitigating evidence on the appropriate penalty to be imposed (reclusion perpetua versus death).

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)