Facts:

The case involves Bernardo Gonzales as the accused appellant and the People of the Philippines as the plaintiff/appellee. The incident occurred on February 7, 1982, in Caloocan City, Metro Manila. Gonzales was charged with the murder of Alberto de Guzman y Piniano, who was attacked while sleeping in the driver’s seat of a parked passenger jeepney. The information filed against Gonzales alleged that he, without justifiable cause and with deliberate intent to kill, attacked de Guzman with a kitchen knife, inflicting multiple stab wounds that ultimately led to the victim's death at the Manila Central University Hospital.

During the trial, Gonzales pleaded not guilty, and the prosecution presented three key witnesses: Myrna de Guzman (the victim's mother), Juliana Flores (an eyewitness), and Cpl. Paulino Batarina (the investigator). The prosecution's evidence included the testimony of Flores, who witnessed the stabbing from a distance of about two arms' length a...

Facts:

Incident Details

• On February 7, 1982, at around 11:00 AM, Alberto de Guzman was sleeping in the driver's seat of a parked passenger jeepney along Katarungan Street, Bagong Barrio, Caloocan City.
• Bernardo Gonzales, the accused, stabbed Alberto multiple times with a kitchen knife. The attack was witnessed by Juliana Flores, who was about two arms-length away from the jeepney.
• Alberto, severely wounded, rushed to his house and informed his mother, Myrna de Guzman, that Gonzales had stabbed him. He was taken to Manila Central University Hospital but died during surgery.

Witness Testimonies

• Juliana Flores: She saw Gonzales stab Alberto and identified him as the assailant. She delayed reporting the incident but later testified in court.
• Myrna de Guzman: Alberto’s mother testified that her son repeatedly named Gonzales as his attacker while being transported to the hospital.
• Cpl. Paulino Batarina: The investigating officer confirmed the stabbing and the victim’s death but was unable to interview Alberto before his death.

Medical Evidence

• The Medical Certificate (Exh. 'D') described multiple stab wounds on Alberto, including wounds to the chest, chin, cheek, arm, and leg, as well as internal injuries like a lacerated diaphragm and perforated colon.

Appellant’s Actions

• Gonzales fled after the stabbing and remained at large for eight years, evading arrest until 1990. He did not present any evidence in his defense during the trial.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Credibility of Juliana Flores’ Testimony:

   • The delay in Flores’ reporting of the incident did not undermine her credibility. Eyewitnesses often hesitate to get involved in criminal investigations, and her identification of Gonzales as the assailant was clear and consistent.
   • Her proximity to the scene (two arms-length away) and her certainty in identifying Gonzales reinforced the reliability of her testimony.

2. Admissibility of the Victim’s Ante Mortem Statement:

   • The victim’s repeated identification of Gonzales as his attacker while being transported to the hospital was admissible as an ante mortem statement. The nature and severity of his wounds indicated he was aware of his impending death, satisfying the legal requirement for such statements.

3. Flight as Evidence of Guilt:

   • Gonzales’ disappearance for eight years after the crime was strong evidence of guilt. The Court rejected his argument that flight must occur immediately after the crime, ruling that the act of fleeing to evade responsibility, regardless of timing, is indicative of guilt.

4. Appreciation of Treachery:

   • Treachery was properly appreciated as a qualifying circumstance. The attack was sudden and unexpected, rendering the victim defenseless as he slept. The absence of any prior confrontation or opportunity for the victim to defend himself established the presence of treachery.