Title
People vs. Villacorta
Case
G.R. No. 186412
Decision Date
Sep 7, 2011
A man appeals his murder conviction after stabbing a victim, but the court finds him guilty of only slight physical injuries due to lack of intent to kill, while still appreciating treachery as an aggravating circumstance.
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Case Digest (G.R. No. 186412)

Facts:

  • The People of the Philippines filed a case against Orlito Villacorta for the crime of murder.
  • On June 21, 2002, Villacorta was charged with stabbing Danilo Salvador Cruz on January 23, 2002, in Navotas, Metro Manila.
  • The incident occurred at 2:00 AM while Cruz was ordering bread at Cristina Mendeja's sari-sari store.
  • Villacorta, armed with a sharpened bamboo stick, stabbed Cruz on his left side without saying a word and then fled.
  • Cruz received outpatient treatment at Tondo Medical Center and was later admitted to San Lazaro Hospital on February 14, 2002, where he died the next day due to tetanus infection secondary to the stab wound.
  • Villacorta denied stabbing Cruz, claiming he only boxed Cruz after Cruz put his arm around Villacorta's shoulder.
  • The Regional Trial Court (RTC) of Malabon found Villacorta guilty of murder, qualified by treachery, and sentenced him to reclusion perpetua.
  • The Court of Appeals affirmed the RTC's decision.
  • Villacorta appealed to the Supreme Court, arguing the prosecution failed to prove his guilt beyond reasonable doubt, that treachery was improperly appreciated, and that he should only be liable for slight physical injuries.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court found that the prosecution proved Villacorta's guilt beyond reasonable doubt.
    • The evidence and eyewitness testimony were credible and sufficient.
  • The Court upheld the finding of treachery as an aggravating circumstance.
    • The attack was sudden, giving Cruz no chance to defend himself.
  • The Court ruled that Villacorta should only be held liable for slight physical injuries due to the lack...(Unlock)

Ratio:

  • The Supreme Court affirmed the credibility of the prosecution's eyewitness, Cristina Mendeja, who identified Villacorta as the assailant.
    • The trial court's assessment of witness credibility is given significant weight.
    • Inconsistencies in Mendeja's testimony were deemed inconsequential to the fact that Villacorta stabbed Cruz.
  • Villacorta's denial was weak and uncorroborated.
  • The Court found merit in Villacorta's argument regarding the proximate cause of Cruz's de...continue reading

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