Title
People vs. Inggo y Tambula
Case
G.R. No. 140872
Decision Date
Jun 23, 2003
Appellant convicted of homicide, not murder, after stabbing victim during an argument; treachery unproven, damages adjusted, sentence reduced.
murder
police framing
credibility of eyewitnesses
A

Case Summary (G.R. No. 229680)

Factual Background

The prosecution established that on August 15, 1996, Rosemarie Reinante asked her parents-in-law’s house helper, Leonisa Insic, to go to her house in Poblacion Katipunan to do household chores. Leonisa Insic complied and, around 1:00 p.m., she returned to Rolando Reinante, Sr.’s house where she lived, went to the kitchen for lunch, and observed that someone bought a bottle of beer from Rolando Reinante, Sr.’s store, then being tended by Lando Tangga, another housekeeper.

Leonisa Insic later identified the buyer as appellant. According to her, appellant paid P50.00 for the beer. Because there was not enough cash to change the bill, Lando Tangga asked Leonisa Insic to change the P50.00 into smaller denominations. Leonisa Insic did so and returned to the store, but Tangga refused to accept the money and instructed her to give the change to appellant instead. Leonisa Insic approached appellant to give the change, but appellant refused to accept it and insisted on receiving his full P50.00. An exchange of words followed between appellant and Leonisa Insic.

While the argument continued, Rosemarie Reinante arrived. She asked for the money and offered to give it to appellant, but appellant still refused and the exchange escalated into an argument. The prosecution narrated that appellant suddenly rushed to Rosemarie Reinante, loosened and removed his belt, and then chased Rosemarie as she ran. When he caught up, appellant stabbed her. Leonisa Insic attempted to intervene by holding appellant’s hands, which allowed Rosemarie to run toward the road. Appellant nonetheless escaped Leonisa Insic’s grasp, chased Rosemarie again, and then fled toward the direction of the cemetery. Leonisa Insic later saw Rosemarie fall when she reached the road, reported the incident to others in the house, and stated that she was afraid to return to the place where Rosemarie fell.

Police authorities later arrived, and together with Leonisa Insic they brought Rosemarie to the Dipolog City hospital. Rosemarie was pronounced dead on arrival.

Defense Version

Appellant testified as his sole witness. He claimed that he was an ice cream vendor and that on the day of the incident he traveled from Katipunan to Roxas to sell ice cream, after which he took lunch in the public market, drank tuba, and returned along the same route, continuing to sell his wares until around 4:00 p.m. When he was near the crossing by the cemetery of Katipunan, appellant stated that three armed men waylaid him, brought him to the police station without showing any resistance, and took off his clothing. He alleged he was not informed of his right to counsel or the right to remain silent. He further claimed he was brought to a provincial hospital around 6:00 p.m. for an examination of his breathing and later returned to detention.

Appellant also asserted that while detained he was boxed and mauled by two police officers, one of whom he identified as Rodel Castillon, and that he became unconscious due to injuries sustained. He claimed that upon regaining consciousness he noticed a stabbing wound on his stomach and could not remember the person who stabbed him. He denied ownership of the prosecution exhibits, including clothing, a belt allegedly containing a hidden knife, a towel allegedly carried, and a stainless hunting knife. Appellant denied knowing the victim and her husband, and denied knowing prosecution witnesses Leonisa Insic and Lando Tangga. He maintained that he did not see those persons on August 15, 1996 because he was selling ice cream in Roxas.

RTC Proceedings and Conviction

On the basis of the testimonies and exhibits, the RTC ruled that the prosecution evidence was credible and sufficient to establish appellant’s guilt beyond reasonable doubt. The RTC found appellant guilty of murder as a principal by direct participation, and it appreciated treachery as a qualifying circumstance, sentencing him to death. It ordered the payment of P500,000 as consequential damages, P100,000 as moral damages, and costs, in favor of the heirs of the victim.

Issues Raised on Appeal

Appellant assigned several errors, which the Court distilled into the core issues of (a) whether his guilt was proven beyond reasonable doubt, and (b) whether the death penalty was properly imposed. To resolve these, the Court also had to assess the credibility of the witnesses and the testimony on the qualifying circumstances.

Arguments of the Parties

Appellant argued that he was merely “framed-up” by the police and insisted that police officers could not locate the real perpetrator. He pointed to the stabbing wound he claimed to have sustained during detention as supporting alleged police machinations. He also contended that even assuming he stabbed the victim, treachery was not established because the victim provoked him by arguing about his attempt to force acceptance of a small amount of change; he further argued that the assault was frontal and thus could not be considered sudden and unexpected.

The Office of the Solicitor General countered that appellant’s frame-up claim was self-serving and uncorroborated. It maintained that two eyewitnesses positively identified appellant and that treachery attended the commission of the crime because the victim did not know appellant had a knife hidden in his belt. It insisted that even if an argument occurred, the victim could not anticipate that appellant would stab her.

Credibility, Identification, and the “Frame-up” Claim

The Court reiterated the controlling principle that the trial court’s findings on witness credibility are accorded great weight and respect and will not be disturbed absent a showing that the trial court overlooked facts and circumstances materially affecting the result. The Court held that there was no compelling reason to depart from this rule.

It found that appellant’s denial and frame-up allegation could not overcome the prosecution’s positive identification by Leonisa Insic and Lando Tangga. The Court emphasized that Leonisa Insic categorically pointed to appellant in open court as the same man who bought beer, refused to accept his change, and later stabbed Rosemarie to death. It noted that Leonisa Insic, although a house helper with limited education, testified in a candid and straightforward manner and that her affidavit had been explained to her in the vernacular and she affirmed that she understood it and signed because it was true.

The Court also credited Tangga’s testimony as corroborative. Tangga stated that he explained to appellant the beer’s value and the resulting change, but appellant refused to accept the change and insisted it was insufficient. Tangga asked Leonisa Insic to explain and return the change, but appellant still would not accept it. Tangga then saw Rosemarie arrive, get money from Leonisa, and attempt to give it to appellant. Tangga testified that appellant then rushed toward Rosemarie and stabbed her on her stomach.

The Court further found no reason for the two witnesses to falsely testify. It noted that no ill motive was shown, and it held that the fact that Rosemarie’s husband, Rolando Reinante, Jr., was present when the witnesses gave statements did not taint their credibility. The Court reasoned that a grieving husband would want the real perpetrator punished, and that absent evidence of motive to perjure, the logical conclusion was that no improper motive existed.

Regarding appellant’s claim that he was merely passing through, the Court observed that he offered no supporting witness. It credited the testimony of Edmundo Ballares, who stated that while he was at the cemetery he saw a police officer pursuing a man from the highway toward the cemetery, and that the police caught up with the man and Ballares assisted by holding his hands and bringing him to the road. The Court held that Ballares’s account withstood grueling cross-examination and that appellant’s denial, being negative and self-serving, deserved no greater evidentiary weight than affirmative testimony from credible witnesses.

On alleged maltreatment by the police, the Court held that appellant’s assertions remained uncorroborated. He presented no medical certificate of injury traceable to any mauling and did not file any criminal or administrative charge against the officers. The Court also noted that the prosecution presented a medical certificate that appellant’s stab wound was self-inflicted, and in the absence of clear and convincing proof to the contrary, the Court applied the presumption of regularity in the performance of official duties.

Treachery Not Proven; Conviction Reduced to Homicide

While the Court affirmed that evidence sustained appellant’s responsibility for stabbing Rosemarie to death, it disagreed that treachery was proved.

It held that the qualifying circumstance of treachery cannot be presumed and must be proved as sufficiently as the crime itself. It reiterated that treachery or alevosia exists when the offender employs means, methods, or forms in the execution that tend directly and specially to insure execution without risk arising from the defense that the offended party might make. It added that to establish treachery, the prosecution must show: first, that at the time of the attack the victim was not in a position to defend herself; and second, that the accused consciously adopted the particular means or method of attack.

The Court found the prosecution failed to adequately show these requisites. It reasoned from the eyewitness account that appellant first chased Rosemarie before he inflicted the fatal stab. Leonisa Insic testified that after appellant loosened his belt and took it off his waist, he chased Rosemarie at a swing and later stabbed her. From this narration, the Court held that Rosemarie tried to run away and appellant caught up with her, but it was not convinced that treachery attended the stabbing.

The Court stressed that the stabbing was not instantaneous. It was preceded by h

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