G.R. No. L-59919 - Malayan Insurance Co., Inc. vs. Court of Appeals

On or about 23 September 2001, in Tacloban City, accused-appellant Decito Francisco y Villagracia was charged with murder in an Information dated 24 September 2001.
The charge detailed that the accused, with deliberate intent, treachery, evident premeditation, and using a deadly weapon (a 13-inch knife known locally as "pisao"), attacked Jaime Noriega III, inflicting stab wounds that eventually caused the victim’s death.

The event occurred during a card game (Lucky Nine) at a wake held for the daughter of Anacleto Noriega in Baybay, San Jose, Tacloban City at around 10:00 p.m.
According to witness Pacifico Daantos, the victim was seated at a table when the accused suddenly approached from behind.
The accused stabbed the victim on his left side, causing him to fall; subsequently, the accused removed the knife from the victim’s body and fled while still holding the weapon.
Witness Francis Elias corroborated that the victim was at the edge of the table and had a clear line of sight to the attack, noting that the accused came from behind and executed the stab.
Despite attempts by Daantos (the victim’s uncle) to pursue the accused, the latter evaded capture until apprehended later by the police while crossing a street in Manlurip, San Jose, Tacloban City.
The victim was brought to a hospital, where he eventually died in the early hours of 24 September 2001 due to massive blood loss.

The accused claimed that at 6:30 p.m. on the same day he was at McArthur Park, and later took passengers to VicMar Beach Resort.
After the drop-off, he waited for the ride companions who eventually did not return and, subsequently, went to meet his friend Martin for drinks at around 7:00 p.m.
He contended that around 10:00 p.m., while riding his pedicab, two strangers accosted him; one of them stabbed him in the left arm while the other struck him with an iron pipe.
In self-defense, he claimed that he managed to stab one of the assailants with a short bolo before the attackers fled.

At trial, the Regional Trial Court (Branch 6, Tacloban City) found the accused guilty of murder, ruling that his self-defense claim was unsubstantiated due to his failure to prove any injuries.
The court noted that under established procedure, any injuries would have been documented during his immediate post-arrest body search and medical examination.
The trial court emphasized the element of treachery, given the accused’s sudden approach from behind, leaving the victim no opportunity to defend himself.
The Court of Appeals (CA) later affirmed the murder conviction, relying heavily on the clear and corroborated testimonies of witnesses Daantos and Elias regarding the sequence of events.

On appeal, the accused contended that the witnesses could not have accurately identified him, arguing that the victim’s body obstructed their view and that the prosecution failed to prove a deliberate method to neutralize the victim’s defense.
Ultimately, the Supreme Court (Third Division) resolved that while the facts as established by the trial and appellate courts were correct, the element of treachery was not proven beyond reasonable doubt.
As a result, the accused’s conviction was downgraded from murder to homicide with a modified penalty and revised awards for civil indemnity and moral damages, and the award for exemplary damages was deleted.

Whether the evidence presented by the prosecution established, beyond reasonable doubt, that the accused committed the killing of Jaime Noriega III.
Whether the testimonies of witnesses Daantos and Elias were sufficient to confirm the accused’s presence and actions during the stabbing incident.

Whether the method or mode of the accused’s attack, coming suddenly from behind, qualifies as treachery by deliberately eliminating any risk of self-defense by the victim.
Whether the accused’s failure to prove the alleged injuries that would support his claim of self-defense undermines the imputation of a planned, treacherous attack.

Whether the original imposition of reclusion perpetua for murder with the attendant award of damages should stand, or if a downgrade to homicide with adjusted penalties and awards is appropriate based on the evidence regarding treachery.