G.R. No. 169246 - People vs. Guzman y Bocbosila

The victim, Michael Angelo Balber y Castillon, a 17-year-old minor with aspirations of becoming a pilot to support his siblings’ education, was fatally attacked on November 25, 1999, in Quezon City.
The killing occurred during a violent brawl in a public area near Sto. Niño Street and Mactan Street, Barangay Commonwealth, with several persons present and active in the altercation.

Ronald Santiago, a jeepney driver, testified that after having a meal at a nearby carinderia, he observed the accused, Nicolas Guzman y Bocbosila, along with two unidentified companions, surrounding and attacking Michael.
Edgardo Bauto, a tricycle driver, corroborated witnessing the stabbing incident where the accused and his companions, using a knife (or possibly a single knife transferred among them), engaged in a coordinated stabbing of Michael at close range.
Danilo Balber, Michael’s father, testified that he saw Michael lying on the street and noted the presence of the accused and his companions nearby. He attempted to pursue them and even threw stones in an effort to catch them.
Police Inspector Alberto Malaza recounted that upon noticing a commotion near his vehicle on his way home, he observed the stabbing action and apprehended the accused immediately after the attack, noting that the assailants were armed.
SPO3 Samuel Quinto, the investigating officer, confirmed that he secured the statements of the prosecution witnesses shortly after Michael was transported to hospital, only to be declared dead.
Dr. Francisco Supe, Jr., the medico-legal officer, presented detailed post mortem findings which established that Michael died of hemorrhage and shock due to multiple fatal stab wounds, with wounds primarily inflicted on the trunk, including injuries that lacerated vital organs.

The accused claimed that on the night of November 25, 1999, he was inside his store when he heard a commotion outside.
He testified that he saw individuals including Danilo and Ronald involved in a brawl, and that Michael had approached his store seeking information about the disturbance.
According to his account, another person, Lemuel, was responsible for the stabbing of Michael while the accused merely observed from his premises.
Antonio, a former bus driver and associate of the accused, supported the assertion that the accused was inside his store at the time, although his testimony lacked corroboration in the records.

The Regional Trial Court (RTC) of Quezon City, Branch 69, in Criminal Case No. Q-99-88737, found the accused guilty beyond reasonable doubt of murder qualified by treachery.
The RTC sentenced the accused to suffer reclusion perpetua (with initial imposition as reclusion perpetua to death) and ordered him to pay actual, moral, and civil indemnity damages to Michael’s heirs.
A Notice of Appeal was filed by the accused on November 26, 2001, prompting the Court of Appeals to render a decision on February 28, 2005, modifying the penalty to reclusion perpetua only.

The prosecution witnesses presented some minor inconsistencies in their narratives—such as differences in the number of knives involved and details regarding the apprehension by Inspector Malaza—but all consistently identified the accused as one who stabbed Michael.
These minor discrepancies were attributed to the natural variances in perception due to the traumatic and chaotic nature of the incident.

The testimonies established that Michael was unarmed, unsuspecting, and unable to defend himself against the coordinated attack by three assailants, including an adult accused against a minor victim.
The evidence indicated treachery in the modus operandi—where the accused and his companions deliberately ensured their own safety while leaving Michael defenseless—and established that the killing was sudden, overpowered, and vicious.

The defense had originally proposed four witnesses in the pre-trial order; however, only two (the accused and Antonio) testified on behalf of the defense.
The RTC denied the defense’s motion to substitute the two absent witnesses, emphasizing that the pre-trial order binds the parties, except when modification would prevent manifest injustice.

Whether the lower courts erred in finding the accused guilty beyond reasonable doubt despite minor discrepancies and inconsistencies in the testimonies of the prosecution witnesses.
Whether such discrepancies, given the traumatic context, should have negated the overall credibility of witness identifications.

Whether the court erred in not giving exculpatory weight to the evidence presented by the defense, particularly the alibi that the accused was inside his store when the incident occurred.
Whether the defense evidence—supported by Antonio’s testimony—was sufficiently credible to raise reasonable doubt.

Whether the trial court violated the accused’s due process right by denying his counsel’s motion to substitute or present additional witnesses who failed to appear as designated in the pre-trial order.
Whether the pre-trial order’s binding effect on the admissibility of witnesses was rightly applied in this case.

Whether the lower courts erred in appreciating the element of treachery in the killing of Michael, specifically regarding whether the means employed by the accused and his companions insured their safety against any risk of retaliation.
Whether the circumstances of the incident—despite occurring in a well-lit area with other people present—nonetheless satisfy the requirements for treachery under the Revised Penal Code.