Case Summary (G.R. No. 123172)

Incident Overview

• On October 9, 1992, Felix de Guia y Quirino and Ricardo Pagadura invited Luzon Madarang for a drinking spree.
• Madarang became intoxicated and fell asleep on a bench.
• At approximately midnight, both de Guia and Pagadura stabbed Madarang multiple times.
• De Guia was apprehended shortly after, with a blood-stained fan knife and bloodstains on his clothing.

Trial Court Proceedings

• De Guia was charged with murder and presented an alibi as his defense.
• The trial court convicted him of murder, sentencing him to reclusion perpetua.
• De Guia appealed the conviction, contesting the credibility of the prosecution's evidence.

Credibility of Witnesses

• The Supreme Court emphasized that appellate courts generally defer to the trial court's assessment of witness credibility.
• The trial court's findings were upheld as they aligned with the evidence presented.

Testimony of Eyewitness

• Greta Amihan Erese, an eyewitness, provided a credible account of the stabbing.
• Her testimony was characterized as categorical, straightforward, and consistent, lacking any apparent motive to lie.
• Erese's account was corroborated by other witnesses, enhancing its credibility.

Inconsistencies in Testimony

• De Guia argued that Erese's testimony contained inconsistencies that undermined her credibility.
• The Court found these inconsistencies to be minor and inconsequential, reinforcing the authenticity of her testimony.

Detailed Testimony and Autopsy Correlation

• Erese's detailed recollection of the stabbing, including the number of stab wounds, was supported by autopsy findings.
• The autopsy confirmed the victim sustained multiple stab wounds, aligning with Erese's testimony.

Initial Reluctance of Witness

• Erese's initial reluctance to come forward was deemed common and did not affect her credibility.
• Her eventual testimony in court was clear and direct, positively identifying de Guia as the assailant.

Circumstantial Evidence for Conviction

• The Court outlined the requirements for a conviction based on circumstantial evidence, which were met in this case.
• The totality of circumstantial evidence presented by the prosecution pointed to de Guia's guilt beyond a reasonable doubt.

Defense of Alibi

• De Guia's alibi was deemed weak as it did not demonstrate physical impossibility of being at the crime scene.
• The defense lacked credible corroboration from disinterested witnesses, further undermining its validity.

Qualifying Circumstances of the Crime

• The Court found that the crime was committed with treachery, as Madarang was attacked while defenseless.
• The trial court's initial finding of abuse of superior strength was deemed incorrect, as it...continue reading