G.R. No. 123102 - People vs. Espina

On July 1, 1993, around 12:00 midnight, appellant Madelo Espina y CaAasares, a 17-year-old jeepney conductor, was implicated in the killing of Ma. Nympha Belen y Melano, a 21-year-old mentally retarded woman.
The killing occurred in San Jose del Monte, Bulacan where the incident took place near a garage in Francisco Homes.

Prosecution witness Tolentino A. Colo, while sleeping inside a jeepney parked in a garage, was awakened by a cry from inside a nearby hut.
Colo observed appellant emerging from the hut holding a curved knife with his t-shirt, hands, and the knife drenched in blood.
Under the illumination of a mercury lamp positioned about three meters away, Colo identified the victim, Ma. Nympha Belen, inside the hut.
Appellant allegedly shouted phrases indicating identification of both the victim ("panglima ire") and Colomb ("panganim ka") which, according to testimony, linked him directly to the incident.
When Colo tried to intervene, he hid by jumping onto the roof of a nearby house and remained there for approximately five hours before continuing his usual route.

On July 2, 1993, Colo was arrested by the police and subsequently made statements identifying appellant as the killer.
The next day, appellant was charged with murder via an Information filed on August 3, 1993, which alleged that he attacked and fatally wounded the victim with apparent premeditation, abuse of superior strength, and treachery.
During the arraignment on October 29, 1993, appellant pleaded not guilty.
Evidence at the pre-trial conference included sworn statements, a post-mortem report, and the victim’s death certificate.

Mrs. Precila Melanio-Belen (mother of the victim) testified about the victim’s condition and the funeral expenses incurred, indicating the victim’s mental retardation.
Tolentino A. Colo provided a detailed account of the events, including his observation of appellant with a bloodied knife at the scene.
SPO3 Rogelio Encina and Dr. Juan V. Zaldariaga, Jr. testified regarding the knife’s presentation as evidence and the post-mortem findings, respectively.

Appellant testified in his own behalf, recounting that he was with a group drinking at a garage when he later inadvertently ended up sleeping inside a parked jeepney.
During police custody at around 12:10 in the morning, appellant claimed ignorance about the identity of the killer.

On September 4, 1995, the Regional Trial Court of Bulacan, Branch 14, rendered a decision convicting appellant of murder.
The court sentenced appellant to reclusion perpetua (at that time the maximum penalty for murder) and imposed indemnity and damages against him:

The present appeal was filed on the ground of alleged errors in witness credibility assessments and insufficiency of circumstantial evidence, as well as the imposition of indemnity amounts.

Whether the trial court erred in giving full faith and credence to Colo’s testimony despite his possible status as a suspect and his prior quarrel with appellant over money.
Whether the witness’s behavior before and after the incident (i.e., not immediately reporting the crime and resuming his jeepney route) should have lowered his credibility or been disqualifying under existing evidentiary rules.

Whether the chain of circumstantial evidence—ranging from appellant’s presence at the locus criminis, his bloodied appearance, the presentation of the murder weapon, and his incriminating remarks—was sufficient to convict appellant of murder beyond reasonable doubt, even in the absence of direct evidence.
Whether the aggregate of proven circumstances meets the legal requisites (multiple corroborative facts, proven inferences, and exclusivity of the hypothesis of guilt) required for a conviction based on circumstantial evidence.

Which qualifying circumstance actually elevated the killing to murder: abuse of superior strength, evident premeditation, or treachery.
Whether the evidence sufficed to establish the elements of evident premeditation and treachery, or if only abuse of superior strength was applicable.

Whether the trial court erred in failing to adequately mitigate the penalty due to appellant’s age (17 years) at the time of the commission of the crime.
Whether the proper penalty should be adjusted pursuant to the privileged mitigating circumstance of minority as provided under existing legal standards and the Indeterminate Sentence Law.

Whether the award for indemnity, actual, and moral damages was properly and sufficiently supported by the evidence concerning the victim’s funeral expenses and the suffering of the victim’s family.