G.R. No. 125761 - Malbarosa vs. Court of Appeals

Accused, Charlie Nazareno y Melanios, was charged with murder before the RTC of Manila, Branch 41.
The information alleged that on or about September 23, 2001, in Manila, the accused willfully and feloniously attacked Romeo de Guzman y Canapit with a bolo, inflicting mortal wounds.
The crime was committed with intent to kill, treachery, and evident premeditation, as evidenced by the nature of the attack (stabbing on the chest and hacking the ear).

At approximately 3:30 a.m. on September 23, 2001, Jericho Capanas, the eyewitness, was awakened by a noise outside his residence at V. Mapa St., Sta. Mesa, Manila.
Capanas observed the accused engaged in unruly behavior in front of a neighbor’s house, including breaking bottles and damaging the window jalousie.
The accused then proceeded to the victim’s house, kicked the door, and when the victim emerged, attacked him by grabbing his hair and thrusting a bladed weapon approximately 20 inches long into his chest.
Capanas, stationed less than an arm’s length away, witnessed the entire incident, noting that the victim was caught unprepared, with his house closely adjacent to Capanas’ own.
After the stabbing, the accused hurriedly left the scene; Capanas then called the police and assisted in transporting the victim to the University of the East Ramon Magsaysay Medical Center (UERMMC).

Responding initially to a disturbance call, Police Station 8 dispatched officers Lawrence Hofer and Joseph Claderia, assisted by a barangay tanod, to the scene.
Upon arrival, they found the accused, covered in blood and still holding the bloody bolo.
The barangay tanod effected the arrest and the accused was taken to the station and later to UERMMC.
At the hospital, the victim positively identified the accused as his assailant.

Dr. Romeo Salen, the medico-legal officer, testified that the victim sustained two stab wounds – one on the right ear and one on the chest, the latter being the direct cause of death.
The autopsy findings corroborated the eyewitness account regarding the nature and location of the wounds.

The accused offered an alternative narrative, stating that on the evening of September 22, 2001, he had been enjoying a drinking spree with the victim and two others.
According to his testimony, an argument ensued when the victim, armed with a bladed weapon, urged him to take revenge on an enemy; a struggle over the weapon led to the victim falling.
The accused claimed he left the scene with the bolo still in his possession.
Additionally, the accused admitted in a letter written on October 14, 2001, addressed to the victim’s brother, asking for forgiveness – an admission later deemed equivalent to a judicial admission of guilt.
On re-direct examination on September 26, 2005, he further confirmed his involvement, stating in simple terms that he did kill the victim.

The trial court found the prosecution’s version, particularly the eyewitness and medico-legal evidence, credible and convicted the accused of murder, sentencing him to reclusion perpetua.
The court also ordered payment of civil indemnity for both the life of the victim and moral damages.
On intermediate appellate review, the Court of Appeals affirmed the conviction but modified the award on the civil aspect by adding exemplary and temperate damages.
The accused raised issues regarding the sufficiency of proof of his guilt, the credibility of the eyewitness testimony, and the finding of treachery.

Whether the accused’s guilt had been proven beyond reasonable doubt given the conflicting versions of the events.
Whether the complaints regarding inconsistencies in the eyewitness testimony were material enough to undermine the prosecution’s case.

The issue of whether Jericho Capanas’ account was reliable given his alleged inconsistencies.
Whether the minor discrepancies in his testimony affected the overall substantive evidence regarding the commission of the crime.

Whether the manner of the killing—attacking a victim who was asleep and therefore defenseless—adequately established treachery.
Whether the circumstances surrounding the victim’s vulnerability (waking from sleep, intoxication) warranted the imposition of the qualifying circumstance of treachery.