G.R. No. 249832 - People vs. Monico Badillo

The accused-appellant is Monico Badillo, initially charged with murder under Article 248 of the Revised Penal Code.
The victim was Joseph Olbes, who was fatally stabbed on September 14, 2008, at Barangay San Juan, Municipality of Irosin, Province of Sorsogon.

Badillo was charged in an Information dated September 17, 2008, alleging that on or about September 14, 2008, at around 7:12 p.m., he stabbed Olbes with treachery and evident premeditation, using a bladed instrument (knife), causing the latter's immediate death.

The prosecution presented three witnesses: Salvador Fernandez, Jomel Escasinas, and Marilou Olbes.
Salvador testified he was fishing near the victim's house when he heard a loud noise, saw Badillo stab the victim multiple times in the upper stomach at the victim's kitchen area, under adequate lighting allowing positive identification.
Jomel corroborated the incident, having seen Badillo at the victim’s gate before his store visit, and later, seeing Badillo leaving the victim’s house holding a blood-stained knife, with sufficient lighting for identification.
Marilou, the victim's wife, testified about her husband's stabbing and eventually dying on the same day after hospitalization.
Dr. Maurice Ellison conducted a post-mortem examination, finding multiple injuries secondary to hacking and stabbing, with the cause of death being cardiorespiratory failure due to hypovolemic shock from exsanguination.

The accused denied the charge and claimed alibi.
Badillo and two witnesses, Felipe Basig and Emilio Badillo (his cousins), testified that Badillo was at Emilio's house in Batuan, Masbate, assisting his daughter requiring medical attention at the time of the incident.
They asserted Badillo left San Juan, Irosin in 2006 and never returned, opposing the possibility of his presence at the crime scene in 2008.

RTC found Badillo guilty of murder with the qualified circumstance of treachery.
The court credited the prosecution's positive identification and dismissed defense testimonies as flimsy due to familial relationship.
RTC sentenced Badillo to reclusion perpetua with indemnities and damages to the heirs.

Badillo appealed to the CA, contesting the credibility of the prosecution witnesses and claiming the absence of treachery and evident premeditation.
The CA affirmed the conviction but downgraded the offense from murder to homicide, ruling lack of evidence on treachery.
CA imposed an indeterminate penalty from six years and one day to 14 years, eight months and one day imprisonment.

Badillo filed a Notice of Appeal to the Supreme Court, which treated it as a petition for review on certiorari due to procedural misstep.
Issues were framed regarding the credibility of witnesses and qualification of the killing as murder due to treachery.

Whether the CA correctly sustained the RTC's findings on the credibility of prosecution and defense witnesses.
Whether treachery attended the killing, qualifying the offense as murder rather than homicide.
Proper determination of penalty and damages.