Title
Pacu-an vs. People
Case
G.R. No. 237542
Decision Date
Jun 16, 2021
Petitioner convicted of homicide for stabbing Zaldy Milad; mitigating circumstances of voluntary surrender and provocation applied; positive witness testimony upheld over defense claims.
A

Case Summary (G.R. No. 180388)

Facts of the Case

On July 31, 2003, an Information was filed against petitioner and his co-accused, Rommel Abao, charging them with homicide for the death of Zaldy Milad. The Information alleges that on the evening of July 29, 2003, both accused, armed with a knife and a stone, attacked Zaldy, inflicting fatal injuries. Petitioner surrendered to the police, was arraigned, and pleaded not guilty. The trial commenced after pre-trial, with testimonies presented by the prosecution corroborating the fatal attack on Zaldy.

Prosecution Evidence

The prosecution's case included testimony from Zaldy's widow, Alicia Milad, and their son, Alvin Milad, as well as a medico-legal expert, Dr. Robert P. Marcelo. Alicia witnessed the stabbing from a distance and identified petitioner as the assailant. She recounted how she called for help and how Zaldy was subsequently transported to a hospital where he was pronounced dead. Alvin corroborated his mother's account, identifying petitioner as holding a knife during the incident. Dr. Marcelo's autopsy confirmed the cause of death as a stab wound to Zaldy's chest, with additional injuries consistent with an assault.

Defense Version

The defense presented witnesses, including Rommel and petitioner, who provided a narrative that diverged from the prosecution's account. Rommel claimed that Zaldy was aggressive and attacked first, wielding a knife. Petitioner affirmed that he acted only in response to Zaldy's aggression. Testimonies included claims that petitioner attempted to separate the parties involved and that other individuals were responsible for Zaldy's death. Such assertions aimed to establish a defense of self-defense or at least to create reasonable doubt about the identity of the true assailant.

Ruling of the Regional Trial Court (RTC)

The RTC found petitioner guilty beyond reasonable doubt of homicide, whereas Rommel was acquitted. The court deemed the testimonies of Alicia and Alvin credible, particularly noting that witnesses saw petitioner fleeing the scene with a knife. The RTC acknowledged mitigating circumstances of voluntary surrender and provocation, imposing a prison term and damages to Zaldy's heirs.

Ruling of the Court of Appeals (CA)

The CA upheld the RTC's decision, agreeing with its assessment of witness credibility and the elements of the crime. The CA found that inconsistencies in Alicia’s testimony did not undermine her credibility. However, it modified the imposed penalty, amending the civil damages awarded, specifically deleting unsubstantiated burial expenses and replacing them with an award for temperate damages.

Supreme Court Findings

In examining the case, the Supreme Court reviewed the petitions regarding the CA's affirmance of guilty verdicts and the alleged weaknesses in witness identification. It ruled that minor inconsistencies do not inherently discredit witness testimony if material elements corroborate the crime's commission. The Court underscored that both the RTC and CA had appropriately assessed the evidenc

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