Title
People vs. Arca
Case
G.R. No. 135857
Decision Date
Jun 18, 2003
Appellant Adriano Arca stabbed Rommel Godornez to death in 1997. Prosecution witnesses testified to treachery; defense claimed mistaken identity. Court affirmed murder with treachery, mitigated by voluntary surrender, imposing reclusion perpetua and damages.

Case Summary (G.R. No. 135857)

Charges and Proceedings

Adriano Arca faced charges under an Information dated July 17, 1997, alleging that he, with evident premeditation and treachery, unlawfully attacked Rommel Godornez using a sharp weapon, resulting in the latter's death. Upon his arraignment on September 25, 1997, Arca pled not guilty. The prosecution presented several witnesses, including Donald Arnulfo, Reynaldo Afable, Susan Agda, and Milagros Godornez, the victim's mother, to corroborate their claims about the circumstances surrounding the stabbing.

Evidence Presented by the Prosecution

The prosecution's case relied heavily on eyewitness testimonies. Witness Donald Arnulfo testified that he witnessed the stabbing while he, the victim, and others were at the victim's house for a barrio fiesta. He described seeing Arca approach the victim and stab him in the back. Police Officer Reynaldo Afable testified about his response to the incident and described how he apprehended Arca, who was still armed at the time. Furthermore, the prosecution presented a post-mortem examination report from Dr. Edgardo Juaban, detailing the cause of death as a result of stab wounds inflicted on the victim.

Defense Testimony

Arca's defense included testimony from his brother, Roberto Arca, who claimed that another individual, Romeo Arca, was actually responsible for the murder. This testimony aimed to cast doubt on the prosecution's case by suggesting that his brother was not involved. The defense also contended that the prosecution witnesses had conflicting accounts and that they were not reliable.

Assessment of Credibility

The trial court found the testimonies of the prosecution witnesses credible and consistent, providing a clear picture of the events leading to Godornez's death. The defense arguments centered on general denials and allegations that the prosecution witnesses were mistaken or had ulterior motives were insufficient to undermine the weight of the eyewitness testimonies. The court emphasized that the findings of the trial judge, who had the opportunity to observe witness demeanor, should be accorded deference.

Treachery as a Qualifying Circumstance

The court discussed the presence of treachery as a qualifying circumstance for murder, noting that even a frontal attack could manifest treachery if it was unexpected and targeted an unarmed victim. The court determined that the victim had no forewarning of the attack due to his position at the time of the stabbing, which constituted treachery.

Sentencing and Modifications

The trial court originally sentenced Arca to death, finding him guilty of murder due to the aggravating circumstance of treachery. However, in reviewing the case, the court recognized the mitigating circumstance of voluntary surrender on Arca's part when he turned himself in to police without resistance. Consequently, the Supreme Court modified the sentence to reclusion perpetua as the more appropriate penalty for murder as m

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