Facts:

The case involves the People of the Philippines as the plaintiff-appellee against Francisco M. Judavar, the defendant-appellant. The events leading to the case transpired on February 15, 1995, at approximately 2:30 AM in Caranday, Baao, Camarines Sur, during a public dance celebrating Valentine's Day. The victim, Arnel Dato, was attending the dance with his girlfriend, Margie Malazarte. At around 2:00 AM, Margie briefly left Arnel's side, during which time Judavar approached Arnel from behind and stabbed him with a ten-inch knife, inflicting a fatal wound to his right chest. Witnesses, including Margie, identified Judavar as the assailant, and he fled the scene immediately after the attack.

The prosecution presented six witnesses who corroborated the events of the stabbing, establishing that the attack was premeditated and executed with treachery. The motive for the murder was rooted in jealousy, as Judavar had previously expressed animosity towards Arnel due to a ...

Facts:

Incident Details

• On February 15, 1995, at around 2:30 AM, Arnel Dato was stabbed to death during a public dance at Caranday Public Market, Baao, Camarines Sur.
• The dance was part of a Valentine's Day celebration sponsored by the Senior Citizens of Caranday.
• Arnel Dato was standing alone, watching the dance, when accused-appellant Francisco M. Judavar approached him from behind and stabbed him with a ten-inch knife, hitting his right chest.

Witness Testimonies

• Margie Malazarte, Arnel’s girlfriend, witnessed the stabbing and identified Judavar as the attacker.
• Francisco Cabalquinto, a barangay tanod, saw the stabbing and was subsequently stabbed twice by Brigido Bustarda, a friend of Judavar.
• Nardito Dato, the chief barangay tanod, chased Judavar but failed to catch him. He later reported the incident to the police.
• Dr. Ruperto Alfelor, the Municipal Health Officer, confirmed that the cause of death was hemorrhagic shock due to the stab wound.

Background of the Rivalry

• Judavar and Arnel Dato were rivals for the affection of Margie Malazarte, their high school classmate.
• Margie chose Arnel over Judavar, which angered Judavar. Prior incidents included Judavar punching Arnel and threatening to kill him if he did not leave Margie.

Aftermath

• Arnel Dato was declared dead at the hospital. His family spent P70,000 for his wake and funeral.
• Judavar fled the scene and could not be located for over two years until his arrest in Iriga City in August 1997.

Defense

• Judavar claimed he was not involved in the stabbing and alleged that the victim was killed during a commotion by an unidentified person.
• He presented Juansus Botor as a witness, who testified that they saw a man with an icepick stab someone, but they did not recognize the attacker.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Murder Qualified by Treachery: The attack was sudden and unexpected, with Arnel Dato having no opportunity to defend himself. This qualifies the killing as murder under Article 248 of the Revised Penal Code.
2. No Evident Premeditation: While there was evidence of prior hostility between Judavar and Arnel, the prosecution failed to prove that the killing was planned with cool reflection and deliberation.
3. Credibility of Witnesses: The testimonies of the prosecution witnesses were credible, consistent, and corroborated by physical evidence. The fact that some witnesses were relatives of the victim did not render their testimonies biased.
4. Flight as Evidence of Guilt: Judavar’s flight after the incident and his prolonged absence from Caranday indicated consciousness of guilt.
5. Damages: The awards for civil indemnity and moral damages were in line with jurisprudence. However, the actual damages were reduced due to insufficient evidence for some expenses claimed.