Title
People vs. Mendoza y Zapanta
Case
G.R. No. 115809
Decision Date
Jan 23, 1998
Taxi driver Danilo Manalus was fatally stabbed by Melvin Mendoza, who claimed self-defense but was convicted of robbery with homicide based on witness testimony, circumstantial evidence, and his admission of needing money for his child.

Case Summary (G.R. No. 115809)

Facts of the Case

On February 15, 1992, at around 10:30 p.m., Danilo Manalus was fatally attacked and stabbed near the Pangilinan Compound along Congressional Avenue, Barangay Bahay Toro, Quezon City. Eyewitness Bonifacio Wycoco, a tricycle driver, apprehended the accused-appellant at the crime scene, while Manalus was later declared dead upon arrival at the hospital. The prosecution's case was built on the testimonies of several eyewitnesses, including Wycoco and Louie Jose, who testified regarding the events they witnessed during the crime.

Prosecution Evidence

Witnesses testified that they saw the accused-appellant attacking the victim with a knife. Wycoco described how he intervened by attempting to pull the accused away from the victim while Jose physically restrained him. The police investigation revealed that Mendoza was in possession of blood-stained money and a knife at the time of his arrest. The victim's autopsy indicated fatal stab wounds, confirming that the incident resulted in homicide. Further evidence of blood found on weapons and cash, along with witness testimonies about the incident, contributed to the prosecution's argument for robbery with homicide.

Defense Arguments

In his defense, the accused-appellant claimed he acted in self-defense, stating that Manalus had aggressively confronted him about taxi fare disputes. Mendoza insisted that the real confrontation occurred after he was asked to alight from the taxi. He contended that the fatal stabbing was a result of a struggle instigated by the victim. The accused's narrative, however, contradicted the testimonies of the witnesses, who reported observing him attacking the driver.

Trial Court Findings

The trial court evaluated the credibility of the testimonies from both the prosecution and the defense. It found considerable inconsistencies in Mendoza’s account compared to the compelling evidence and testimonies provided by the prosecution witnesses. The court ruled against the self-defense argument, siding with the corroborated accounts of the eyewitnesses who had no evident motive to falsify their testimonies.

Legal Analysis

The two main assignments of error raised by the accused-appellant were dismissed by the court. First, the claim that eyewitnesses lacked direct knowledge of the robbery was rejected, as their observations of the violent attack during the robbery were sufficient to establish intent. The second contention, questioning the ownership of the blood-stained money, was also dismissed, as the evidence strongly indicate

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