Facts:

The case involves Felix de Guia y Quirino as the accused-appellant and the People of the Philippines as the plaintiff-appellee. The incident occurred on October 9, 1992, in Quezon City, Philippines, where the victim, Luzon Madarang y Padilla, was fatally stabbed multiple times. The Regional Trial Court of Quezon City, Branch 92, rendered a decision on August 14, 1995, convicting de Guia of murder, qualified by abuse of superior strength, and sentenced him to reclusion perpetua. The court also ordered him to pay the heirs of the victim P50,000.00 as indemnity for death, P19,573.00 for funeral expenses, and P30,000.00 as moral damages.

The prosecution's case was built on the testimony of six witnesses, including an eyewitness, Greta Amihan Erese, who observed the stabbing incident. Erese testified that she saw de Guia and another individual, Ricardo Pagadura, simultaneously stab Madarang while he was asleep on a bench. The victim was later pronounced dead on arrival at th...

Facts:

Incident Details

• On October 9, 1992, at around 8:00 PM, accused-appellant Felix de Guia y Quirino and Ricardo Pagadura fetched Luzon Madarang from his house for a drinking session near the creek at Squatter’s Area, Fema Road, Sitio Pajo, Baesa, Quezon City.
• At around 12:00 midnight, Greta Amihan Erese, an eyewitness, was walking to a friend’s house to attend a wake when she saw Luzon Madarang sleeping on a bench. She witnessed accused-appellant and Pagadura stab Madarang multiple times with a balisong knife, causing his death.
• Madarang was pronounced dead-on-arrival at Quezon City General Hospital due to multiple stab wounds.

Arrest and Investigation

• On October 10, 1992, at around 1:00 AM, police officers responded to reports of the stabbing. Residents led them to a safehouse where they found accused-appellant, drunk and sleeping, with bloodstains on his clothes and a bladed weapon in his possession.
• Accused-appellant was arrested and charged with murder.

Prosecution’s Evidence

• The prosecution presented six witnesses, including Greta Amihan Erese, who positively identified accused-appellant as one of the perpetrators. Other witnesses testified on the circumstances of the crime, the autopsy results, and the damages incurred.

Defense’s Version

• Accused-appellant denied knowing the victim or being present at the scene. He claimed he was at home asleep at the time of the incident. His alibi was corroborated by Norberto Saliling, his aunt’s husband, and Eduardo Tuano, his employer.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Credibility of Witnesses: The Court upheld the trial court’s assessment of the credibility of Greta Amihan Erese, whose testimony was categorical, straightforward, and consistent. Her positive identification of accused-appellant as the perpetrator outweighed his denial and alibi.
2. Direct Evidence vs. Circumstantial Evidence: The Court found that the prosecution’s evidence, particularly Erese’s eyewitness account, constituted direct evidence of accused-appellant’s guilt. Even if circumstantial evidence were considered, the totality of the circumstances pointed to his guilt.
3. Defense of Alibi: The Court rejected accused-appellant’s alibi, as he failed to prove physical impossibility of being at the crime scene. His alibi was also uncorroborated by disinterested witnesses.
4. Qualifying Circumstance: The Court ruled that the crime was attended by treachery, as the victim was asleep and unable to defend himself. Abuse of superior strength was absorbed by treachery.
5. Damages: The Court affirmed the award of P50,000.00 as indemnity for the victim’s death and P19,573.00 for funeral expenses. However, the moral damages were reduced from P30,000.00 to P20,000.00.