G.R. No. L-48642 - People vs. Salcedo

On or about June 24, 1999, at Barangay Impalutao, Impasugong, Bukidnon, appellant Edgar Dumadag y Cagadas was charged with murder.
The charge arose from the stabbing of Fernando Prudente, which resulted in a mortal wound on the victim’s breast.
The stabbing was allegedly committed with a stainless knife “with intent to kill by means of treachery,” as stated in the Information.

The event occurred on a rainy afternoon during the feast of St. John when Fernando Prudente and his friends, including Marlyn Meliston, were returning from a celebration at the Gantungan swimming pool.
Prudente and his companions took shelter at a store owned by Mr. Salva, where they encountered two men, one of whom was the appellant.
After offering Prudente a drink of Tanduay—which Prudente declined by saying “Bay, I am not drinking now”—the appellant became irritated.
The appellant followed Prudente, seized his right shoulder, and stabbed him, causing an immediate fatal injury.
The eyewitness, Jovy Baylin, testified that he observed the sequence of events, including the stabbing and the subsequent escape of the appellant toward the lower area of Cagayan de Oro.
Medical evidence from Dr. Leslie Joan M. Arcadio corroborated that the cause of death was a stab wound to the right chest.

He testified that on the afternoon of June 23, 1999, he was at Vista Villa, Sumilao, Bukidnon, pursuing money-making schemes.
He claimed to have been involved in labor activities at a ricefield with Richard Masicampo, Sr., including cutting grass and having lunch.
It was further asserted that due to a heavy downpour, he and his companion stayed in the house drinking, and he fell asleep after consuming several bottles of afighter wine.
He stated that he awoke at 5:30 p.m. and then went home.

The defense argued that he could not have been at the scene of the crime, although he admitted at a pre-trial conference that he was in the vicinity.
The appellant’s alibi was weakened by his admission—made during the pre-trial—that he was at the scene at the time of the crime and by his inability to conclusively prove physical impossibility of being present.

During the pre-trial conference held on November 4, 1999, the appellant, with his counsel, admitted to being near the scene, an admission that was reduced into writing and later signed and approved by the trial court.
Under Section 5 of Republic Act No. 8493 (The Speedy Trial Act of 1998), such stipulations were binding and controlled the course of the trial.
The trial court, after weighing the evidence and testimonies, rendered a judgment on November 21, 2000, convicting the appellant of murder with treachery and imposing corresponding penalties.

Was the single eyewitness testimony of Jovy Baylin sufficient to establish beyond reasonable doubt that the appellant stabbed the victim?
Can the quality of testimonial evidence override the inconsistencies in the appellant’s alibi?

Did the trial court err in dismissing the appellant’s alibi defense, notwithstanding its inherent weakness?
Was there a failure to prove with clear and convincing evidence that it was physically impossible for the appellant to be at the scene?

Whether, even assuming the guilt of the appellant for the killing, the prosecution failed to prove beyond reasonable doubt the presence of treachery, thereby warranting a conviction for murder instead of homicide.
Whether the absence of premeditation and the suddenness of the attack justified diagnosing only homicide under Article 249 of the Revised Penal Code.

Whether the award of moral damages amounting to P50,000 was justified given there was no proof of wounded feelings, mental anguish, or similar injuries to the heirs.
If not, what is the appropriate quantum of damages (temperate damages) to be awarded?