Facts:

The case revolves around Joemarie Jalbonian alias "aBudoa," who was accused of murder under Criminal Case No. 917 filed on July 30, 1991. The charge was initiated in the municipality of Ilog, Negros Occidental, for the unlawful killing of Fortunato Quintanilla, Jr. The act was alleged to have taken place on January 26, 1991, during a barangay assembly held at Balicotoc Elementary School, where witnesses observed the confrontation between the accused and the victim. Oscar Valenciano, the barangay chairman present during the incident, testified that he saw the appellant stab Quintanilla in the back with a knife, resulting in the victim's death shortly thereafter. The appellant eluded capture for over five years until apprehended on July 10, 1996, at which point he pleaded not guilty during his arraignment. His trial commenced without presenting any defense evidence after the prosecution put forth its case, relying heavily on Valenciano's eyewitness testimony, whi

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Facts:

Filing of the Information and Facts of the Crime

• An Information for murder was filed on July 30, 1991 against appellant Joemarie Jalbonian alias aBudoa.
• The accusatory portion alleged that on January 26, 1991 in Ilog, Negros Occidental, appellant, armed with a bladed weapon, attacked and stabbed Fortunato Quintanilla, Jr. on the back with evident premeditation, treachery, and intent to kill.
• The fatal stab wound inflicted on the victim's back caused his death.
• Appellant went into hiding for more than five years and was later apprehended on July 10, 1996.

Prosecution’s Evidence and Testimony

• Barangay Chairman Oscar Valenciano testified as the lone prosecution witness.
• He attended a barangay assembly held at Balicotoc Elementary School on the morning of January 26, 1991.
• After the meeting, while leaving the school premises, he observed from about three extended arms’ length the appellant positioning himself behind the victim and stabbing him.
• He immediately ordered a member of the Citizens Armed Forces Geographical Unit (CAFGU) to pursue the appellant, though the latter managed to elude capture.
• The account provided by Valenciano was detailed, mentioning the precise timing, location, relative distances, and the sequence of events during the commission of the crime.
• A death certificate, issued by Dr. Ricardo P. Garrido, Rural Health Officer of Ilog—which noted that the victim died on January 26, 1991 due to shock and hemorrhage from a stab wound—was introduced and served as corroborative physical evidence.

Proceedings Before the Lower Courts

• During arraignment, the appellant entered a plea of not guilty.
• The trial ensued in the Regional Trial Court (RTC), Branch 61, Kabankalan City, Negros Occidental.
• After the prosecution rested its case, the defense filed a Motion for Leave to File a Motion to Dismiss (by way of Demurrer to Evidence), which was denied by the trial court on May 14, 2002.
• The RTC rendered a decision on March 5, 2003, convicting appellant of murder qualified by treachery, relying heavily on Valenciano’s testimony and the aforementioned death certificate.
• Appellant filed a Notice of Appeal, and the case was elevated for intermediate review in accordance with People v. Mateo.

Court of Appeals (CA) and Appellate Proceedings

• The CA, in its June 7, 2007 Decision, affirmed the conviction of the appellant but modified the RTC’s judgment by ordering the appellant to pay exemplary damages to the victim’s heirs.
• The CA increased the recovery for civil indemnity to the victim’s heirs in the appellate ruling.
• The appellant's sole contention on appeal was that his conviction was based on insufficient evidence, particularly questioning the credibility and accuracy of the lone prosecution witness’s account.

Criticisms and Arguments Presented by the Parties

• Appellant’s Arguments
• Claimed that relying solely on the testimony of one witness (Valenciano) was insufficient to establish guilt beyond reasonable doubt.
• Argued that if Valenciano was following the victim, his view would not have allowed a clear identification of the assailant’s face, especially since the attack was carried out from behind with the victim’s back turned.
• Maintained that the nature of the fatal wound does not automatically indicate treachery, asserting that there was no evidence that the stabbing from behind was meant to preclude any chance of defense.
• Claimed that Valenciano’s uncorroborated testimony raised doubts as to its reliability.
• Prosecution’s (Office of the Solicitor General) Arguments
• Asserted that the single testimony of a credible and familiar witness is sufficient for conviction.
• Stated that the physical proximity to the scene, the witness’s familiarity with the accused as Barangay Captain of the locality, and the corroborative evidence of the death certificate all strengthen the credibility of Valenciano’s account.
• Contended that the sudden and unprovoked nature of the stabbing, which deprived the victim of an opportunity to defend himself, clearly established the element of treachery.

Issue:

Sufficiency of Evidence

• Is the testimony of the lone prosecution witness, if credible and detailed, sufficient to establish the guilt of the accused beyond reasonable doubt?
• Does the absence of corroborative witnesses undermine the weight of Valenciano’s testimony?

Credibility and Reliability of the Lone Witness

• Can the witness’s identification of the accused, given the physical position and circumstances of the crime, be relied upon?
• Is the relative position of the witness to the victim and accused a valid basis to question his credibility?

Establishment of Treachery as an Attendant Circumstance

• Does the manner in which the victim was attacked (stabbed on the back) satisfy the legal elements required for murder qualified by treachery?
• Is there sufficient evidence to prove that the act was executed without any chance for the victim to defend himself?

Appropriateness of the Awarded Penalties and Damages

• Are the sentences and additional awards (civil indemnity, exemplary, moral, and temperate damages) proportionate and in accordance with the findings of the lower courts and relevant jurisprudence?

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

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