G.R. No. 254251 - People vs. Conde y Mina

The case involves an Information charging Danilo Conde y Mina with Murder under Article 248 of the Revised Penal Code for the killing of Reynaldo Adlawan y Antonio.
The incident is alleged to have occurred on or about February 24, 2013, in San Mateo, Rizal, during a drinking session where the accused, armed with a kitchen knife, suddenly attacked and stabbed the victim on the chest.
The charge includes aggravating circumstances such as treachery, evident premeditation (although later disputed), and an allegation of nighttime aggravation.

Three key eyewitnesses—Jeffrey Atibagos, Rogelio Cabangisan, and Mary Jane Cabangisan—provided testimonies:

Jeffrey testified that during a casual conversation at Mary Jane’s house, he observed the accused abruptly stab Reynaldo without any preceding provocation.
Rogelio corroborated that the accused, while casually conversing, suddenly attacked the victim with a concealed knife, leaving Reynaldo no time to defend himself.
Mary Jane confirmed witnessing the incident firsthand, noting that the stabbing occurred during the drinking session.

A Police Officer (PO3 Cornelio B. Giwao) testified that when the accused was arrested, he was in possession of the knife used in the stabbing, substantiating the eyewitness observations.

The accused vehemently denied stabbing Reynaldo, arguing that he was invited to join a drinking spree at an ihawan where he eventually became intoxicated and fell asleep in a waiting shed.
According to the defense, he was later awakened and informed by his companions that he had stabbed Reynaldo, thereby attempting to establish an alibi and claim a frame-up scenario.
The defense maintained that it was inconsistent with human behavior for him to commit such a violent act immediately after a drinking session with close friends without any prior provocation.

The RTC, in its decision dated July 4, 2017, found the accused guilty beyond reasonable doubt of Murder, convicting him with treachery and evident premeditation, and sentencing him to reclusion perpetua.
Monetary awards were imposed: initially Php 50,000.00 each as death indemnity and moral damages.
On appeal, the Court of Appeals (CA) in its Decision dated August 16, 2019, affirmed the conviction, modifying the decision by:

Recognizing only the qualifying circumstance of treachery.
Increasing the monetary awards to Php 100,000.00 each for civil indemnity and moral damages, adding Php 100,000.00 as exemplary damages and Php 30,225.00 as actual damages.

The accused-appellant, through his subsequent appeals and manifestations, reiterated his denial and alibi despite the strong evidence presented by the prosecution.

Whether the Court of Appeals erred in affirming the trial court’s decision by giving substantial weight to the prosecution witnesses’ consistent and credible testimonies against the accused.
Whether the appellate court erred in disregarding the accused-appellant’s defenses of denial and alibi, particularly given his claim that his involvement in a drinking spree rendered it irrational for him to suddenly commit murder.