G.R. No. 95818 - Sy vs. Court of Appeals

The crime occurred on or about August 11, 1997, in the Municipality of Malabon, Metro Manila.
Accused-appellant Edwin Bayotas y Imperio was charged with the murder of Ricardo CaAo, having been found guilty by the Regional Trial Court, Branch 70, Malabon.
The stabbing was carried out with a fan knife (balisong), with intent to kill, and under circumstances alleged to involve treachery, evident premeditation, and the use of superior strength.

The events leading to the crime began with an altercation between the victim and the accused-appellant.
The victim initially fled to the barangay hall, where both parties were persuaded to sign an amicable settlement by local barangay tanods.
Despite reconciliation efforts, resentment allegedly persisted on the part of the accused-appellant.

After the purported settlement at the barangay hall, accused-appellant left ahead of the victim.
He subsequently armed himself with his fan knife and concealed himself in a dark corner along M.H. Del Pilar Street, Panghulo, Malabon.
As the victim boarded a jeepney for transportation, the accused-appellant managed to board the vehicle covertly.
Inside the jeepney, he suddenly attacked the victim by stabbing him, inflicting multiple wounds.
Barangay tanod Jessie Soriano, who witnessed the incident, intervened by pulling the accused off the jeepney and slamming him onto the pavement, although the accused-appellant then fled.
The assailant was later apprehended by the police, and his fan knife, recovered by Soriano and submitted as evidence, was marked as Exhibit D.

The postmortem examination revealed a series of stab wounds inflicted on the victim:

A stab wound in the right infraclavicular region that fractured the 2nd right thoracic rib and pierced the upper lobe of the right lung.
A stab wound in the left mammary region.
A fatal stab wound in the left anterior axillary region that fractured the 7th left thoracic rib and pierced the lower lobe of the left lung.
Incised wounds on the right thumb and right hand.

Dr. Maria Cristina B. Freyra testified that the wound in the left anterior axillary region was fatal and, like the others, was caused by a single-bladed weapon.
The defense’s presentation included the accused-appellant as the sole witness detailing his account, admitting to the act but attributing it to a fit of anger over his wife’s alleged infidelity with the victim and a disputed cockfighting-related transaction.

During the trial, both the prosecution and the defense presented divergent narratives of the events.
The prosecution’s case was bolstered by the eye-witness testimony of Jessie Soriano, whose account described how the accused-appellant surprised the victim in the jeepney despite appearing to have reconciled at the barangay hall.
On December 10, 1991, the trial court rendered its decision finding the accused-appellant guilty beyond reasonable doubt for murder qualified by treachery, imposing reclusion perpetua and ordering payment of P50,000.00 as civil indemnity plus P60,000.00 as actual damages.
The appeal raised various issues, including the characterization of treachery, alleged mitigating circumstances, and the propriety of awarding actual damages without sufficient substantiation.

Whether the trial court correctly appreciated and applied the qualifying circumstance of treachery in the commission of the murder.

The accused-appellant argued that the presence of other passengers and earlier reconciliation negated treachery.
The issue revolves around whether waiting in ambush and launching a sudden and unexpected attack from a dark corner satisfied the elements of treachery.

Whether the trial court erred in disregarding the purported mitigating circumstances raised by the accused-appellant.

These include claims of passion, obfuscation, and vindication of a grave offense, as well as the allegation of voluntary surrender.
The court had to determine if any such circumstances could diminish the accused’s criminal liability.

Whether the trial court properly evaluated the credibility of the witnesses, particularly balancing the self-serving testimony of the accused-appellant against that of the disinterested barangay tanod Jessie Soriano.

Whether the award of actual damages amounting to P60,000.00 was justified in the absence of documentary evidence such as receipts, and if the award of moral damages was properly considered.