G.R. No. 252267 - Encinares y Ballon vs. People

The case involves the People of the Philippines versus Fernando Muerong y Fajardo.
On January 13, 1996, during a wedding celebration in Barangay Tangcarang, Gerona, Tarlac, several individuals, including Rudy Pascua, Ricardo Madriaga, Sergio Cadiente, and Florante Facun, were drinking gin at Ella Bautista’s store beside Pablo Agustin’s house.
Appellant Fernando Muerong, a 50-year-old carpenter, arrived after dark and joined the group already engaged in drinking.
The group shared one glass for drinking, and during his turn, the appellant drank from it and twice poured the remaining liquor on Rudy Pascua’s head.

After being assisted by persons who took him home approximately 100 meters from the gathering, the appellant was later boxed and taken away by individuals from the group.
An hour after his initial participation, appellant returned to the scene without being noticed.
In an unexpected move, he suddenly approached from behind and stabbed Rudy Pascua with a stainless steel kitchen knife, striking him on the left chest.
During the incident, appellant first restrained Pascua’s hair from behind before executing the stab.

Rudy Pascua was immediately brought to a hospital in Camiling, Tarlac, but was declared dead on arrival due to “hemorrhagic shock” as per his death certificate.
The appellant surrendered to Romulo Vanzuela, Elpidio Raceres, and Barangay Captain Amorsolo Raceres at the municipal building in Gerona, where he also turned over his weapon.
Witnesses, including Cesario Ramos and prosecution witnesses Ricardo Madriaga and Sergio Cadiente, testified regarding the events, highlighting that no one in the group noticed his approach, and that the stabbing was executed suddenly from behind.
At arraignment on September 6, 1996, the accused pleaded not guilty, leading to a full trial on the merits.

The Regional Trial Court (Branch 63, Tarlac) found appellant guilty beyond reasonable doubt of murder based on the testimony of witnesses and the sequence of events.
The killing was determined to be attended by treachery, as it deprived the victim of any opportunity to defend himself.
The elements of evident premeditation were discussed but ultimately not applied against appellant, as the prosecution failed to establish the required criteria for premeditation.
The court imposed the penalty of reclusion perpetua, ordered appellant to indemnify the heirs of Rudy Pascua with Fifty Thousand Pesos (₱50,000.00), and later mandated moral damages amounting to the same sum.

Whether the killing of Rudy Pascua was attended by treachery, thereby qualifying the crime as murder under Article 248 of the Revised Penal Code.
Consideration of whether the victim was forewarned and thus could have defended himself, given that appellant had earlier poured gin on his head.

Whether there was evident premeditation on the part of appellant in committing the killing.
Examination of the prosecution’s failure to substantiate premeditation by proving (a) the time of decision, (b) an act manifesting the offender’s resolve, and (c) a sufficient lapse for reflection.

Whether the testimony and evidence support the assertion that the appellant’s intoxication at the time of the crime should mitigate his liability.
Evaluation of the quantity of alcohol consumed and its alleged effect on his capacity to control his reason.