G.R. No. 112569 - Shuhei Yasuda vs. Court of Appeals

Case Digest (G.R. No. 112569)
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Facts:

Charges and Incident Overview

The accused-appellant, Rogelio Villapando y Bunsol, was charged before the Regional Trial Court of Batangas City with:

Murder in Criminal Case CCC-VIII-823(79).
Attempted homicide in Criminal Cases Nos. 770 and 771.

The informations in the cases alleged that on January 14, 1979, at about 6:10 p.m. on P. Genato St., Batangas City:

In CCC-VIII-823(79): The accused, armed with a fan knife and with intent to kill, attacked Saturno Romulo Manalo y Gabia, striking him fatally.
In Criminal Case No. 770: The accused similarly, with intent to kill and without justifiable cause, attacked Alicia Beron y Panganiban, inflicting a 1 cm incised wound on her forearm which incapacitated her for up to nine days.
In Criminal Case No. 771: The accused attacked Ramon Tolentino y Delgado, inflicting two sutured wounds on his right arm which incapacitated him for more than one month.

Upon arraignment, the accused pleaded not guilty to all the charges.

Narrative of the Stabbing Incident

The events unfolded at the BLTBCo. bus terminal in Batangas City:

Victims (Ramon Tolentino, Nelia Panganiban, and Alicia Beron) had gathered to board a bus for Manila.
Romulo Manalo, Alicia’s boyfriend, accompanied them.

A confrontation arose:

An argument between Romulo Manalo and the accused escalated when they exchanged fist blows.
The altercation moved outside the bus, where a physical tussle ensued.
The accused produced a fan knife and stabbed Romulo; following this, he also lunged at Alicia Beron with three strikes and stabbed Ramon Tolentino twice.
Witnesses testified about the frantic nature of the incident, including chase and attempts to intervene by the victims.

The immediate aftermath:

Romulo Manalo was fatally wounded as the stab wound penetrated his chest, causing cardiac arrest.
The injured survivors and bystanders attempted to stop the violence.
The accused fled the scene, later being apprehended.

Defense and Counter-Narrative

The accused interposed a defense of alibi:

He claimed that he, along with his kumpadre Romy Acedillo, was at a cockpit in San Pablo City at the time of the incident.
He further presented evidence of a Seiko watch purchase with a guarantee booklet dated January 14, 1979, as corroborative proof.
An eyewitness, Paquito Sorizo, was presented by the defense to attest that the accused was not the assailant.

The lower court’s evaluation of the alibi:

Found the alibi to be weak due to inconsistencies in the testimonies regarding the watch purchase.
Considered the testimony of Paquito Sorizo as biased and lacking probative value.

Identification evidence:

Prosecution witnesses, including Ramon Tolentino and Nelia Panganiban, identified the accused.
The identification was made through direct observation (e.g., pointing to the accused in open court) and not through a formal police line-up.
Conflicting descriptions regarding height or other minor details were deemed non-prejudicial.

Lower Court Decisions and Penalty Impositions

For CCC-VIII-823(79):

The accused was sentenced to reclusion perpetua (life imprisonment).
He was ordered to pay indemnity to the heirs of the deceased and to render actual, moral, and exemplary damages.

For Criminal Case No. 770:

The accused was sentenced to twenty (20) days imprisonment.
He was also ordered to pay the costs of the proceedings.

For Criminal Case No. 771:

The accused was sentenced to an imprisonment ranging from six (6) months of arresto mayor to two (2) years and one (1) day of prision correccional.
It was ordered that the most severe penalty be served first, with credit given for any preventive detention.

Issues:

Validity and Sufficiency of the Alibi Defense

Whether the alibi defense, supported by the watch purchase evidence and the testimony of Paquito Sorizo, proved beyond reasonable doubt that the accused was elsewhere at the time of the incident.
Whether the inconsistencies between the defense witnesses (the accused’s account vs. Romy Acedillo’s testimony) undermined the alibi claim.

Credibility and Consistency of Identification Evidence

The reliability of the identification of the accused by the prosecution witnesses on the basis of direct observation.
The weight to be given to the conflicting evidence regarding the physical description (e.g., height) and positioning during the incident.

Determination of the Appropriate Crime and Qualification of the Offense

Whether the crime committed against Romulo Manalo should be qualified as murder (with qualifying circumstances such as treachery or evident premeditation) or as simple homicide.
The applicability of the defense’s contention regarding the absence of treachery given the manner of the stabbing.

Appropriate Sentencing and Classification of Offenses

Whether the penalty of reclusion temporal, with its corresponding range under the Indeterminate Sentence Law, was correctly applied in light of the crime’s aggravating or mitigating circumstances.
Whether the determination of “less serious physical injuries” for the attempted homicide cases (Criminal Cases Nos. 770 and 771) was supported by the facts and the evidence.
The issue of habituality or reiteration, and whether the previous offenses of the accused met the criteria for enhancing the penalty.

Ruling:

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Ratio:

(Subscriber-Only)

Doctrine:

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