Case Summary (G.R. No. 147196)
Indictment
The appellant was charged with murder, claiming that on June 24, 1999, he attacked the victim with treachery using a sharp bladed weapon, inflicting mortal wounds which led to the victim's instantaneous death, thereby damaging the legal heirs of the victim.
Evidence of the Prosecution
The prosecution presented a narrative detailing the events of June 24, 1999. The victim celebrated the feast of St. John with friends at a swimming pool. When a rainstorm hit, they sought shelter at a local store. The appellant and a companion, drinking at the store, encountered the victim, who declined an offer of drinks. Subsequently, the appellant followed the victim, stabbed him in the chest with a stainless knife, and fled. The victim was pronounced dead shortly after being taken to the hospital due to the stab wound.
Evidence of the Appellant
The appellant denied the charges, asserting he was at a separate location with a friend during the time of the incident. His defense included an alibi that he fell asleep after consuming alcohol and claimed to have no knowledge of the victim or witnesses. He was arrested days later at his home.
Present Appeal
In his appeal, the appellant contended that the trial court erred by disregarding his alibi, asserting that such a defense was weak but had not been sufficiently proven against him. He argued that, even if guilty, he should be convicted of simple homicide instead of murder, as the prosecution had failed to prove treachery, a crucial element in the charge of murder.
Arguments from the Office of the Solicitor General (OSG)
The OSG maintained the prosecution's position, highlighting the testimony of the sole witness, Jovy Baylin, outlining the circumstances of the stabbing as a clear act by the appellant. However, the OSG acknowledged that the evidence did not sufficiently establish treachery, suggesting a conviction for homicide instead.
Trial Court's Findings
The trial court, after assessing the evidence, found the appellant guilty of murder, supporting its conclusion with details from Baylin's testimony, which was deemed credible and compelling. The court noted that a single, clear, and positive identification from a credible witness is sufficient for conviction.
Review of Evidence and Alibi
The court assessed the appellant's alibi, determining that it was inadequately supported by clear evidence and, moreover, contradicted by earlier admissions made during pre-trial proceedings which indicated his presence at the crime scene.
Examination of Treachery
The court identified that treachery, a requirement for the charge of murder, had not been adequately proven. Treachery must demonstrate that the assailant used premeditated means ensuring the victim's inability to defend themselves, which was not evident. The suddenness of the attack was attributed to an emotional response rather than a premeditated act, resulting in the conclusion that the killing could only be classified as hom
...continue readingCase Syllabus (G.R. No. 147196)
Background of the Case
- The case revolves around the appeal of Edgar Dumadag y Cagadas against the Decision of the Regional Trial Court of Malaybalay, Bukidnon, which found him guilty of murder.
- The trial court sentenced Dumadag to reclusion perpetua, ordered him to pay civil indemnity and moral damages to the victim's heirs.
The Indictment
- Dumadag was charged with murder under an Information alleging that on June 24, 1999, he attacked and stabbed Fernando Prudente in Barangay Impalutao, Bukidnon.
- The indictment specified that the stabbing was committed with treachery and with intent to kill, resulting in Prudente's instantaneous death.
Evidence of the Prosecution
- The incident occurred during the feast of St. John when Fernando Prudente and friends sought shelter from the rain at a store.
- Dumadag, who was drinking with a companion, offered Prudente a drink, which he declined.
- Following Prudente's refusal, Dumadag attacked him, stabbing him in the chest with a stainless knife.
- Eyewitness Jovy Baylin testified to seeing Dumadag stab Prudente, and Prudente was declared dead upon arrival at the hospital due to a stab wound.
Evidence of the Appellant
- Dumadag denied the charges, claiming he was in Vista Villa, Sumilao, Bukidnon, on the day of the incident and had been cutting grass for a local landowner.
- He asserted that he was asleep at the time of the stabbing and