G.R. No. 118653 - People vs. Villegas

The case involves the People of the Philippines prosecuting Marcos Villegas for the crime of murder.
The accused was charged for having fatally stabbed Lauro de Guzman en route to his residence in Pasig, Metro-Manila on or about December 18, 1989.

According to the accusatory portion of the information, the accused, armed with a hunting knife, approached the victim and inflicted stab wounds with treachery as an attendant qualifying circumstance.
The fatal stabbing occurred when the accused allegedly attacked de Guzman from behind while the victim was traversing from a dark alley to a well-lit area near a MERALCO post.

The Order of Arrest dated May 9, 1990, could not be executed immediately because the accused had left his residence and his whereabouts became unknown.
As a result, the case was archived on February 22, 1991, until the accused was later served following his arrest on August 2, 1993 for a separate offense involving the violation of R.A. No. 6425 (possession of dried marijuana leaves).
The accused, upon arraignment on September 22, 1993, pleaded not guilty.

Eyewitness Lorenzo Marcelo testified that he observed the accused suddenly darting from an alley and stabbing the victim once on the left side of his back.
Eleuteria de Guzman, the victim’s mother, provided background on the victim’s character and circumstances, including details about the expenses incurred for funeral services.
Dr. Dario Gajardo, the medico-legal officer, performed the autopsy and established that the victim’s death was due to shock and hemorrhage from stab wounds.

Notably, discrepancies arose between Dr. Gajardo’s autopsy findings (indicating two wounds) and Marcelo’s testimony (indicating one stab wound), which were explained as due to the fleeting and confusing nature of the attack.

Alibi – Claiming he was plying his tricycle route and later assisted some individuals to go to Marcos Highway.
Denial of the accusation – Asserting that contradictions in the eyewitness testimony and inconsistencies in the evidence created reasonable doubt.

An additional corroborative testimony by Adelo Tena supported the defendant’s version of events, particularly his claim of being engaged in his tricycle driving activities at the time of the incident.

The trial court found the accused guilty beyond reasonable doubt of murder.
The court gave full credence to the testimony of eyewitness Marcelo, noting that his recollections were largely consistent with material facts and partially confirmed by the accused’s own statements.
The trial court also considered the accused’s flight from his residence, deducing that it was indicative of a guilty conscience and supportive of the treachery element charged.
Based on these findings, the trial court convicted the accused, imposing reclusion perpetua along with additional penalties, including indemnity to the victim’s family.

The trial court erred in giving too much weight to the prosecution’s eyewitness, whose testimony was allegedly fraught with doubtful and contradictory elements.
The evidence did not support the finding of treachery, contending that the circumstances (such as the visibility of the incident) negated the element of surprise essential to treachery.

He invoked the presumption of innocence and claimed that the evidence did not meet the required threshold for a conviction beyond reasonable doubt.

Whether the trial court improperly gave undue weight to the testimony of eyewitness Lorenzo Marcelo, whose account was claimed by the accused to contain inconsistencies and contradictions.
Whether the minor inconsistencies in Marcelo’s testimony undermine the overall credibility of the evidence against the accused.

Whether the trial court correctly determined that the manner in which the crime was committed (i.e., the sudden, ambush-type attack) satisfied the requisite elements of treachery under Article 248 of the Revised Penal Code.
Whether the possibility that the victim could have seen the accused approaching negates the element of treachery.

Whether the accused’s disappearance and inability to be served with the order of arrest should be considered evidence of a guilty conscience and thus used to reinforce the conviction.