Title
People vs. Bromo
Case
G.R. No. 97914
Decision Date
Nov 22, 1999
The case involves the stabbing death of Zacarias Lindo. The accused, Joel Bromo, was found guilty of murder qualified by treachery and was sentenced to imprisonment of reclusion perpetua. The court based its ruling on the testimony of the lone eyewitness, Victorina Zuniega, who positively identified the accused as the assailant. The court rejected the defense's claim that another person, Sonny Boy Alejo, was the assailant. The court ruled that the crime committed was murder qualified by treachery, as the assailant attacked the victim from behind without giving him a chance to defend himself.
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Case Digest (G.R. No. 97914)

Facts:

  • The case "People vs. Bromo" involves the fatal stabbing of Zacarias Lindo on March 19, 1983, in Negros Oriental, Philippines.
  • Joel Bromo, alias "Cano," was charged with murder qualified by treachery.
  • The prosecution's key witness was Victorina Zuniega, the sister-in-law of the deceased, who witnessed the stabbing.
  • Victorina testified that Bromo, standing behind Lindo, stabbed him twice with a stainless hunting knife—once on the neck and once on the side.
  • The victim ran into a dance hall, shouting that Bromo had stabbed him.
  • The defense claimed that Sonny Boy Alejo was the actual assailant and presented witnesses to support this claim.
  • The trial court found Bromo guilty, relying on Victorina's testimony and rejecting the defense's alibi and denial.
  • Bromo was sentenced to reclusion perpetua and ordered to indemnify the victim's heirs.
  • Bromo appealed, questioning the credibility of the lone eyewitness and asserting that Alejo was the true assailant.
  • The Supreme Court of the Philippines heard the appeal, with the decision penned by Justice Gonzaga-Reyes on November 22, 1999.

Issue:

  • (Unlock)

Ruling:

  1. The Supreme Court affirmed the trial court's decision, finding no reason to doubt the credibility of the lone eyewitness, Victorina Zuniega.
  2. The Supreme Court rejected the defense's claim that Sonny Boy Alejo was the assailant, upholding the trial court's findings.
  3. The Supreme Court upheld the conviction of Joel Bromo for murder qualified by...(Unlock)

Ratio:

  • The Supreme Court found Victorina Zuniega's testimony credible and consistent with the medico-legal findings.
  • Her account was detailed and corroborated by the physical evidence, including the nature and location of the stab wounds.
  • The Court emphasized that positive identification by an eyewitness carries more weight than the accused's denial and alibi.
  • The dying declaration of the victim, identifying Bromo as his assailant, met all requisites for admissibility under Rule 130, Section 37 of the Rules of Court.
  • The defense's claim that Sonny Boy Alejo was the assailant lacked credibility, as it was not corroborated by ...continue reading

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