Title
Supreme Court
People vs. Petalino
Case
G.R. No. 213222
Decision Date
Sep 24, 2018
Accused stabbed victim during a casual encounter; treachery unproven, conviction downgraded to homicide. Eyewitness testimony outweighed denial and alibi.

Case Digest (G.R. No. 145222)
Expanded Legal Reasoning Model

Facts:

  • Procedural and Charging Background
    • The accused-appellant, Alberto Petalino alias "Lanit", was charged with murder through an information dated February 19, 1998 for killing Johnny Nalangay on November 30, 1997 in Iloilo City.
    • The information alleged that the accused, armed with a knife and employing treachery and evident premeditation, willfully attacked the victim resulting in fatal injuries to vital parts of his body.
  • Prosecution’s Version of Events
    • Eyewitness Testimony by Franklin Bariquit
      • Bariquit, who attended a party in Barangay Danao, Iloilo City, recounted that he met the victim and later accompanied him as they were leaving to secure rides home.
      • While walking down a narrow alley, the victim and Bariquit encountered the accused coming from the opposite direction.
      • According to Bariquit, the accused suddenly turned toward the victim, grabbed his hair, and without warning, stabbed him in the back.
      • Following this, a confrontation ensued between Bariquit and the accused, which led to the accused dropping his knife.
      • Bariquit then sought help while the victim, after attempting to evade, was found lying bloodied on the ground and later pronounced dead at the hospital.
  • Testimony of the Victim’s Father, Jaime Nalangay
    • Confirmed that the victim was 20 years old at the time of his death.
    • Stated that he was informed about his son’s stabbing by a police officer and was present at the hospital, only to find his son had already died.
    • Claimed that he incurred expenses for embalming and burial, and expressed the immeasurable pain caused by the death.
  • Defense’s Version of Events
    • Accused-Appellant’s Testimony
      • The accused testified that on the night of November 30, 1997, he was at his sister’s store in Iloilo City and left after assisting customers.
      • He claimed that upon entering a narrow alley, he encountered two persons, one of whom, a certain Bariquit, called him “Lanit”.
      • He explained that an accidental bump occurred when he turned his back, leading to an unintended collision with the victim, for which he apologized.
      • Allegedly, the victim then became aggressive—boxing him in the chest—causing the accused to lose control and punch the victim in self-defense.
      • The accused claimed that as the victim recovered and drew a knife, a struggle ensued, prompting him to flee when the victim’s companions, who were intoxicated, tried to intervene.
  • Court Decisions Prior to the Supreme Court
    • Regional Trial Court (RTC) Judgment (January 24, 2013)
      • Found the accused guilty beyond reasonable doubt of murder based on the prosecution’s evidence and the credible eyewitness identification.
      • Imposed the penalty of reclusion perpetua along with accessory penalties and civil liabilities, including indemnity, moral, exemplary, and temperate damages to be paid to the victim’s heirs.
  • Court of Appeals (CA) Decision (April 24, 2014)
    • Affirmed the RTC’s ruling, emphasizing that the inconsistencies in the eyewitness testimony were minor and did not undermine Bariquit’s credibility.
    • Upheld the finding that treachery was present in the execution of the crime, thereby justifying the murder conviction.
  • Allegations Raised by the Accused-Appellant on Appeal
    • Argued that his denial and alibi should have prevailed over the positive identification by the eyewitness.
    • Claimed that the qualifying circumstance of treachery did not stand as the prosecution failed to establish the necessary elements for its appreciation.

Issues:

  • Whether the prosecution established the accused-appellant’s guilt beyond reasonable doubt despite his denial and alibi, given the positive identification by the eyewitness.
  • Whether the prosecution sufficiently proved the qualifying circumstance of treachery, particularly that the accused consciously adopted a mode of execution which left the victim without any opportunity to defend himself or retaliate.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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