Case Digest (G.R. No. 168100)
Facts:
People of the Philippines v. Mateo Daleba, Jr., G.R. No. 168100, November 20, 2007, Supreme Court Second Division, Carpio, J., writing for the Court.Around noon on 18 March 1997 at a bus terminal in Pasay City, appellant Mateo Daleba, Jr. and the victim, Renato Angeles, quarreled over division of their earnings as terminal barkers. A bystander, Edwin Bernarte, intervened and pacified them; Renato walked away toward his nearby home. Appellant joined Bernarte’s group to eat, then—according to prosecution witnesses—suddenly ran after Renato, drew a knife, held Renato’s shoulder with his left hand, slashed Renato’s right forearm and stabbed him at the back above the right waistline. Renato died that evening from the stab wound.
Appellant left for his home province in Camarines Sur and was arrested four years later. He was charged before the Regional Trial Court (RTC) of Pasay City, Branch 116 (Criminal Case No. 97-0386), with Murder qualified by treachery and evident premeditation. Appellant asserted self-defense, claiming Renato had earlier assaulted him and that Renato suddenly grabbed his neck and repeatedly struck him with a knife, prompting appellant to pick up a knife and stab in defense.
In a Decision dated 28 February 2002, the RTC convicted appellant of Murder, found treachery present but not evident premeditation, sentenced him to reclusion perpetua, and awarded actual and moral/economic damages; the trial court credited prosecution eyewitnesses Bernarte and Federico Angeles over appellant’s uncorroborated account and treated appellant’s flight as evidence of guilt. Pursuant to People v. Mateo (G.R. Nos. 147678-87), the case was transferred to the Court of Appeals.
The Court of Appeals, in a Decision penned by Associate Justice Jose Catral Mendoza (with Associate Justices Romeo L. Brawner and Edgardo P. Cruz concurring) dated 19 April 2005, affirmed the RTC’s conviction but reduced the indemnity awarded to P50,000 and accepted appellant’s explanation that his flight was motivated by fear of retaliation from Renato’s policeman father. Appellant brought the matter to the Supreme...(Subscriber-Only)
Issues:
- Did appellant prove self-defense such that the homicide is justified?
- Was the killing of Renato qualified by treachery under Article 14(16) of the Revised Penal Code?
- May appellant’s flight be properly considered as evidence of guilt?
- Should exemplary damages be...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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