Case Summary (G.R. No. 126028)
Charges and Incident Details
Alfon was charged with murder based on an information that detailed the incident occurring on February 18, 1993, in Barangay Oring, Caramoan, Camarines Sur, wherein he allegedly stabbed the victim with a fan knife (balisong), resulting in the victim's instantaneous death. The information specified that the act was committed with intent to kill, treachery, and evident premeditation.
Trial and Arraignment
Following his arraignment on July 28, 1993, where he pleaded not guilty, the trial court heard testimonies from four witnesses. The prosecution's case centered around eyewitness accounts detailing the attack and an autopsy report confirming the cause of death as stab wounds.
Eyewitness Testimonies
Vicente Eusebio testified seeing Alfon suddenly stab Alferez while following him, hitting him on the chest and ribs. Manuel Rayoso provided similar testimony, identifying Alfon as the attacker. Dr. Aguirre confirmed in her autopsy findings that the victim sustained two fatal stab wounds and classified the cause of death as profuse hemorrhage secondary to stab wounds.
Defense Strategy and Testimony
Alfon mounted a defense based on denial, asserting that he was not responsible for the stabbing and contending that Rodolfo Alferez had attacked the victim. Alfon stated that he had been pursued by the victim and Rodolfo, asserting that a fistfight led to the fatal stabbing inflicted by Rodolfo. However, his testimony lacked supporting evidence and credibility.
Court Findings and Conclusion
The trial court found the eyewitness testimonies credible and established beyond reasonable doubt that Alfon committed the murder with treachery, rejecting his defense as mere denial without corroboration. The court noted that the testimonials portrayed a planned and unexpected attack, qualifying the act as treacherous despite the frontal nature of the stabbing.
Assigned Errors in Appeal
In his appeal, Alfon alleged errors in the trial court's credibility assessment concerning witnesses, the finding of treachery, and his own liability for damages. The Court examined these claims, affirming the trial court's decision based on the consistency and reliability of the eyewitness accounts and finding treachery present given the circumstances of the attack.
Modifications to Civil Liability
While the Court upheld the civil
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Case Background
- The case revolves around the appeal of Expedito Alfon against the decision of the Regional Trial Court (RTC) of San Jose, Camarines Sur, which found him guilty of murder.
- The RTC sentenced Alfon to reclusion perpetua, ordered him to indemnify the heirs of the victim, Tomas Alferez, with P50,000.00 in civil indemnity, and P24,220.00 in actual damages, along with the costs of the suit.
Charges and Incident Details
- Alfon was charged under an information detailing that on February 18, 1993, at around 2:00 PM in Barangay Oring, Caramoan, he attacked and stabbed Tomas Alferez with a balisong (fan knife), resulting in Alferez's immediate death.
- The information specified the intent to kill, the use of treachery, and evident premeditation.
Eyewitness Testimonies
- The prosecution presented four key eyewitnesses:
- Vicente Eusebio: Witnessed Alfon following Alferez and stabbing him twice from behind. Eusebio shouted for help after the attack.
- Manuel Rayoso: Confirmed seeing Alfon stab Alferez from behind while holding his shoulder.
- Dr. Minerva Aguirre: Conducted the autopsy and testified that Alferez sustained two fatal stab wounds and another injury to his finger, which likely occurred during an attempt to defend himself.
- Rodolfo Alferez: The victim’s brother, who provided testimony regarding the funeral expenses incurred due to the victim’s death.
Defense and Testimony of the Accused
- Alfon's defense was built around den