Case Summary (G.R. No. 181517)
Conviction and Sentence
Ernesto de Guzman was convicted of Murder by the Regional Trial Court of Gapan City on September 25, 2001. The court sentenced him to the penalty of Reclusion Perpetua and ordered him to pay the heirs of the victim P50,000 for moral damages and P50,000 for actual damages.
Factual Background of the Incident
The prosecution's narrative indicates that, on June 14, 1997, around 1:00 a.m., De Guzman confronted Rodrigo during a conversation with several individuals. He mockingly asked Rodrigo if he wanted to borrow a knife before stabbing him. After Rodrigo fled, De Guzman pursued and continued attacking him with a knife, delivering multiple stab wounds even after the victim fell to the ground.
Autopsy Findings
An autopsy performed by Dr. Paquito Alarilla revealed multiple stab wounds, with one penetrating the heart, liver, and lungs, leading to death from severe hemorrhage and shock. Dr. Alarilla indicated that the fatal injury could have caused death within approximately five minutes.
Defense and Alibi
De Guzman denied the charges, presenting an alibi that claimed he was at his mother's house in Riverside, Gapan, and sleep during the timeframe of the incident. His mother corroborated his statements, and a defense witness, Cecilia, reflected that she saw potential witnesses and the victim arguing nearby around the time of the stabbing but did not see De Guzman.
Trial Court's Findings
The trial court found De Guzman’s alibi implausible due to its proximity to the crime scene (15 meters). It emphasized that the prosecution witnesses were credible and familiar with De Guzman, thus discrediting his claims of knowing them. The trial court concluded that the nature and number of stab wounds indicated a clear intent to kill, and that the use of treachery was evident since the victim had no opportunity to defend himself against De Guzman’s sudden attack.
Appeal and Court of Appeals' Decision
Upon appeal, the Court of Appeals upheld the trial court's findings, noting the positive identification of De Guzman by witnesses Garcia and Garces, thus rendering proof of his motive unnecessary. The appellate court also noted the inadequacy of evidence supporting the alibi, while affirming the presence of treachery due to the unprovoked and sudden nature of the attack.
Modification of Damages
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...continue readingCase Syllabus (G.R. No. 181517)
Case Background
- The appellant, Ernesto de Guzman y Elemencio, was convicted of Murder by the Regional Trial Court of Gapan City on September 25, 2001.
- The court sentenced him to Reclusion Perpetua and ordered him to indemnify the heirs of the victim, Felicito Rodrigo, with Fifty Thousand Pesos (P50,000.00) for moral damages and another Fifty Thousand Pesos (P50,000.00) for actual damages.
Accusatory Information
- The Information charged that on June 14, 1997, at approximately 1:00 a.m., in Barangay San Vicente, Gapan, Nueva Ecija, the appellant attacked the victim with intent to kill, employing treachery and cruelty.
- The attack involved multiple stabs to the victim even after he fell, exhibiting deliberate augmentation of suffering.
Prosecution's Evidence
Incident Description:
- On the night of the incident, the appellant was conversing with the victim and others when he suddenly stabbed Felicito Rodrigo with a kitchen knife.
- The victim attempted to flee but was pursued and stabbed multiple times until he fell to the ground.
- A prompt report was made to the police, leading to the appellant's arrest at around 5:00 a.m. the same day.
Autopsy Findings:
- Conducted by Dr. Paquito Alarilla, it revealed multiple stab wounds, particularly one that struck vital organs (heart, liver, lung), causing death within approximately five minutes.