Case Summary (G.R. No. 186227)
Prosecution's Version
The prosecution presented three witnesses: Salvador Fernandez, Jomel Escasinas, and Marilou Olbes. Salvador testified to witnessing Badillo stabbing Joseph Olbes, identifying him positively as the attacker due to the considerable light from the victim's kitchen. Jomel corroborated Salvador's testimony, recounting seeing Badillo leave Olbes's residence with a blood-stained knife. Marilou, the victim's wife, affirmed that her husband was attacked, ultimately dying from his injuries shortly after being taken to two hospitals. A post-mortem examination confirmed the cause of death being multiple injuries resulting from stabbing.
Defense's Version
Badillo's defense rested on denial and alibi. He claimed to have been in Batuan, Masbate, at the time of the stabbing and asserted he was unaware of Olbes prior to the incident. He was supported by two relatives, Felipe Basig and Emilio Badillo, who testified that they were with him at home on the evening of the stabbing. However, the court found their defense unconvincing due to their familial relationship to Badillo.
Ruling of the RTC
On July 7, 2017, the Regional Trial Court (RTC) found Badillo guilty of murder, highlighting the treachery involved in the stabbing, despite Badillo's claim of denial and alibi. The RTC sentenced him to reclusion perpetua and ordered him to pay civil and moral damages to the heirs of the deceased.
Appeal to the Court of Appeals
Badillo appealed the RTC's decision, arguing that the CA erred in its assessment of witness credibility and that there was insufficient evidence to establish treachery. Nonetheless, the CA affirmed the RTC's decision but modified the charge from murder to homicide due to the lack of clear evidence of treachery.
Supreme Court's Assessment
Upon review of the case, the Supreme Court noted that Badillo had incorrectly pursued an appeal through a Notice of Appeal rather than the appropriate petition for review. However, the Court opted to treat the appeal as a petition for review on certiorari for the sake of justice.
The Court upheld the CA's finding that the RTC's witness assessments were credible and reiterated the principle that the trial court's assessment of the witnesses should be given considerable deference. The Court found no reversible error in the conviction and confirmed that the elements of murder, specifically treachery, were not sufficiently proven based on eyewitness accounts. The testimonies lacked detail on how the attack commenced, which disqualified the homicide from being classified as murder.
Penalty and Damages
The Supreme Court modified the punishment, reducing Badillo's sentence to that for homic
...continue readingCase Syllabus (G.R. No. 186227)
Background and Case Antecedents
- Accused Monico Badillo was charged with murder under Article 248 of the Revised Penal Code for the stabbing and death of Joseph Olbes on September 14, 2008, at Barangay San Juan, Irosin, Sorsogon.
- The charge alleged presence of qualifying circumstances of treachery and evident premeditation.
- Badillo pleaded not guilty and the trial included presentation of prosecution and defense witnesses.
Prosecution's Version and Evidence
- Three prosecution witnesses testified: Salvador Fernandez, Jomel Escasinas, and Marilou Olbes, wife of the victim.
- Salvador witnessed Badillo stabbing the victim multiple times at the kitchen of the victim's home around 7:12 p.m., supported by presence of light that enabled identification.
- Jomel corroborated seeing Badillo at the victim's house and later fleeing with a blood-stained knife.
- Marilou attested to the victim’s stabbing, medical treatment, and eventual death on the same day.
- Post-mortem examination by Dr. Maurice Ellison showed death caused by multiple stabbing injuries resulting in cardiorespiratory failure due to hypovolemic shock and exsanguination.
Defense's Version: Denial and Alibi
- Badillo claimed denial and alibi corroborated by relatives Felipe Basig and Emilio Badillo.
- He asserted he was in Batuan, Masbate at the time, assisting his daughter’s medical needs.
- Felipe and Emilio testified that Badillo was present at Emilio’s house in Batuan on the date and time of the incident.
- They emphasized Badillo had not visited or lived in San Juan, Irosin, since 2006.
Trial Court (Regional Trial Court) Findings and Decision
- The RTC found Badillo guilty beyond reasonable doubt of murder, appreciating only the qualifying circumstance of treachery.
- Witness testimonies of prosecution were credited as credible and free from ill-motive.
- The court held the stabbing was sudden and unexpected, rendering the victim unable to defend himself; thus establishing treachery.
- Defense witnesses’ testimonies were viewed skeptically as they were relatives of the accused; their alibi considered flimsy.
- The RTC sentenced Badillo to reclusion perpetua with ci