G.R. No. 135919 - People vs. Delos Santos

On or about November 6, 1997, in the Municipality of San Jose, Del Monte, Bulacan, appellant Danny delos Santos y Fernandez was charged with the crime of murder.
The Information alleged that, armed with a kitchen knife and with evident premeditation, treachery, and taking advantage of superior strength, the appellant attacked Rod Flores y Juanitas.
The attack was described as sudden and brutal, with the appellant stabbing Flores multiple times—including an upward and downward thrust from behind—resulting in mortal wounds.
The injury was so severe that Flores’ intestines visibly bulged out of his stomach, and the stabbing continued until the victim was dead.

Marcelino De Leon testified that he was outside the scene around 8:00 p.m. when he saw Flores drinking “gin” with others and observed the appellant suddenly emerge from behind and stab Flores.
Marvin Tablate corroborated De Leon’s account by confirming that he witnessed the appellant’s involvement and even attempted to separate the victim from the attacker.
Dr. Benito Caballero provided detailed forensic testimony, noting that Flores sustained twenty-one stab wounds (eleven being fatal) with wounds found at specific areas of the body including the back, suggesting the attacker struck from behind.
Romeo Flores testified regarding the victim’s employment situation and expounded on the financial losses incurred by the victim’s family, including significant expenses for burial and funeral services.

The appellant denied the charge, asserting that he was at his auntie’s house in Muson, San Jose del Monte, approximately 40 meters away from the scene, where he was fetching water and watching television with Sonny Bautista.
The defense argued that there was no prior altercation or motive between him and Flores, and questioned the inconsistencies in the prosecution witnesses’ testimonies.

On October 2, 1998, the Regional Trial Court (Branch 21, Malolos, Bulacan) rendered a decision finding the appellant guilty of murder with the qualifying circumstance of treachery.
In its decision, the trial court emphasized the brutality of the killing and sentenced the appellant to suffer the penalty of death by lethal injection.
Additionally, it ordered the appellant to indemnify the heirs of the deceased with specific monetary awards for civil indemnity, loss of earning capacity, actual and compensatory damages, moral damages, and exemplary damages.

The trial court erred in giving undue credence to the testimonies of the prosecution’s eyewitnesses, asserting that inconsistencies therein should have led to an acquittal on the ground of reasonable doubt.
The trial court erred in ordering the indemnification payments to the victim’s heirs, claiming that the evidence did not support such financial awards beyond reasonable doubt.

The appellant maintained that the inconsistencies—such as conflicting time references and details of the altercation—cast doubt on the veracity of the prosecution’s evidence, and that his own alibi should exonerate him.

Whether the trial court erred in placing full confidence in the testimonies of the prosecution witnesses despite alleged inconsistencies.

Sub-issue: Do minor inconsistencies in eyewitness accounts undermine the overall credibility and reliability of the testimonies?

Whether the defense’s alibi and denial created sufficient reasonable doubt to warrant an acquittal.

Sub-issue: Is the absence of a demonstrable motive a basis for acquittal in a case of murder, particularly when positive identification exists?

Whether the trial court committed an error in ordering the payment of indemnification and damages to the victim’s heirs, considering the evidence presented in support of these awards.

Sub-issue: Were the amounts for actual, compensatory, moral, exemplary damages, and loss of earning capacity properly calculated and supported by competent evidence?