G.R. No. 231144 - Republic vs. Sandiganbayan, Special 2nd Division

On or about the 14th of June, 1997, at approximately 1:00 a.m., an altercation occurred in Barangay San Vicente, Municipality of Gapan, Nueva Ecija.
The accused, Ernesto de Guzman y Elemencio, was alleged to have deliberately and unlawfully attacked Felicito Rodrigo with a kitchen knife.

Appellant allegedly initiated the attack by saying, "Eto, gusto mo bang hiramin ito?" immediately before stabbing the victim.
After the initial stab, the victim fled, but the appellant caught up and continued to stab him repeatedly.
As the victim fell face down, the appellant delivered additional stab wounds to the back, demonstrating a clear intent to kill.
The autopsy conducted by Dr. Paquito Alarilla revealed multiple stab wounds, with the wound that struck vital organs (heart, liver, and lung) being sufficient to cause death within approximately five minutes.

Enrico Garcia and Ferdinand Garces testified positively identifying the appellant as the assailant.
Other witnesses present during the conversation, namely Wilson Malgapo and Orlando Navarro, contributed to the detailed account of the incident.

The autopsy report provided detailed descriptions of six wounds on the victim’s body, supporting the prosecution's narrative.
The location of the wounds and the rapid succession in which they were inflicted emphasized the brutality and treachery of the attack.

Immediately following the incident, Garcia reported the crime, prompting the police investigation that led to the arrest of the appellant at his residence at around 5:00 a.m. on the same day.
The trial court (Branch 36 of the RTC in Gapan City) convicted Ernesto de Guzman y Elemencio of murder beyond reasonable doubt and sentenced him to reclusion perpetua.
In addition, the trial court ordered the appellant to pay moral damages and actual damages to the heirs of the victim, as well as civil indemnity.

He had no acquaintance with the victim or key prosecution witnesses (Garcia and Garces).
He was at his mother’s house at Riverside at the time of the stabbing, thus presenting an alibi supported by his mother, Catalina de Guzman.

However, the physical proximity between his residence and the crime scene (approximately 15 meters apart) led to the dismissal of his alibi.
On appeal, the Court of Appeals, modifying a part of the trial court's decision, reduced the award for actual damages while affirming the conviction, emphasizing eyewitness identification and physical evidence over the unsupported alibi.

Whether the eyewitness identifications by Garcia and Garces provided sufficient evidence to overcome the appellant’s denial and alibi.
Whether the prosecution was required to present proof of motive for the killing, given the strong direct evidence of the crime.
Whether the alibi presented by the appellant was credible and whether it established a physical impossibility of his presence at the crime scene.
Whether the use of treachery in the killing—judged by the sudden and repeated nature of the stabbing—was sufficient to qualify the offense as murder rather than a lesser homicide.
Whether the reduction in the award for actual damages by the Court of Appeals was justified based on the proven extent of the victim’s funeral expenses.