Case Digest (G.R. No. 143126)
Facts:
People of the Philippines v. Eric Baltazar y Villaruel, G.R. No. 143126, July 31, 2003, First Division, Azcuna, J., writing for the Court. On appeal is the April 24, 2000 decision of the Regional Trial Court, Branch 109, Pasay City, which found appellant Eric Baltazar y Villaruel guilty of murder under Article 248 of the Revised Penal Code and sentenced him to reclusion perpetua and to indemnify the heirs of the victim in the amount of P50,000.The information charged that on October 14, 1998, in Pasay City, appellant, with intent to kill, with treachery and evident premeditation, stabbed one Roberto Alba y Quianga causing his death. Baltazar pleaded not guilty and was represented by appointed counsel. At trial the prosecution presented four witnesses: PO1 Domerlin Sayson (arresting officer); Rosita La Torre (the victim’s live-in partner and eyewitness); Danilo Alba (victim’s brother); and Dr. Dominique Aguda (post-mortem examiner). Baltazar testified in his own defense, asserting denial and an alibi.
The prosecution’s evidence was that at about 5:00 p.m. on October 14, 1998, Roberto and Rosita sat on a bench in front of their residence when Baltazar suddenly appeared and repeatedly stabbed Roberto; the assault was unexpected, the attacker fled after Rosita shouted for help, and Roberto died later that evening. Rosita gave two police statements, identified Baltazar in court and testified she knew him by the nickname “Toto Tattoo.” Dr. Aguda’s autopsy found seven stab wounds, two of which were fatal—one penetrating the left ventricle and upper lobe of the left lung and another the upper lobe of the right lung; wounds were frontal and inflicted by a single‑edged sharp instrument.
Appellant denied knowledge of the victim, asserted his nickname was “Totoy,” claimed he sold cigarettes and spent October 14 in Monumento Circle (alibi), and narrated his arrest on October 21, 1998, alleging police brutality, identification by Rosita at the station, and an unproven demand for P10,000. The trial court credited the prosecution’s witnesses as positive and categorical, found treachery present despite the frontal nature of the attack because it...(Subscriber-Only)
Issues:
- Was the eyewitness identification by Rosita La Torre reliable and sufficient to overcome appellant’s denial and alibi?
- Was the qualifying circumstance of treachery properly appreciated to elevate the killing to murder under Article 248 of the ...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)