Case Summary (G.R. No. 213222)
Background of the Case
On February 19, 1998, an information was filed against Petalino alleging that he, armed with a knife and with treachery and evident premeditation, stabbed Johnny Nalangay, resulting in the victim's death due to injuries sustained. The Regional Trial Court (RTC) of Iloilo City found the accused guilty of murder based on eyewitness testimony and other evidentiary factors.
Prosecution's Version
The prosecution presented eyewitness Franklin Bariquit, who testified that he and the victim were leaving a party when they encountered the accused. Bariquit observed the accused stab Nalangay unexpectedly from behind. He described the victim's desperate attempt to escape and subsequent collapse after running a short distance. Though the victim managed to speak before losing consciousness, he later succumbed to his injuries in the hospital. The victim's father, Jaime Nalangay, testified regarding the emotional and financial impact of his son’s death.
Defense's Version
In contrast, Petalino denied the charges, claiming that he was initially involved in a verbal altercation with Nalangay after inadvertently bumping into him. He asserted that he acted in self-defense when Nalangay drew a knife, claiming they wrestled for control of the weapon before he fled the scene out of fear of being attacked by the victim’s friends.
Judgment of the RTC
On January 24, 2013, the RTC convicted Petalino of murder and sentenced him to reclusion perpetua. The court ordered him to pay various damages to the victim's heirs, specifying amounts for indemnity, moral damages, exemplary damages, and temperate damages.
Appeals Process
Petalino appealed the decision, arguing that the prosecution did not establish his guilt beyond reasonable doubt and that the circumstances of the crime did not support the claim of treachery. On April 24, 2014, the Court of Appeals upheld the RTC's decision, finding that the inconsistencies in Bariquit's testimony were minor and did not undermine his credibility. The appellate court affirmed the presence of treachery, noting that the manner of the attack denied the victim an opportunity to defend himself.
Supreme Court's Ruling
Upon review, the Supreme Court found merit in the appeal concerning the appreciation of treachery. According to Article 14, paragraph 16 of the Revised Penal Code, treachery requires that the attack must be executed in a manner that ensures the accused faces no risk from the victim's defense. The Court determined that the requirements for proving tre
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Overview of the Case
- This case involves the review of the decision promulgated on April 24, 2014, by the Court of Appeals (CA) affirming the judgment rendered on January 24, 2013, by the Regional Trial Court (RTC) of Iloilo City.
- The accused-appellant, Alberto Petalino alias "Lanit," was found guilty beyond reasonable doubt of murder for the death of Johnny Nalangay.
Antecedents
- The information dated February 19, 1998, charged the accused with murder, alleging he fatally stabbed the victim armed with a knife, with treachery and evident premeditation.
- The incident occurred on November 30, 1997, in Iloilo City, resulting in the victim's death due to injuries inflicted on vital parts of his body.
Prosecution's Version
- Eyewitness Franklin Bariquit testified he attended a party with the victim and decided to leave for home around 1:30 AM.
- Upon passing through a narrow alley, Petalino unexpectedly turned, grabbed the victim's hair, and stabbed him in the back.
- The victim attempted to flee but fell. Bariquit intervened, causing Petalino to drop his knife, after which Bariquit sought help but found the victim bloodied and unconscious.
Defense's Version
- Accused Alberto Petalino claimed he was helping at his sister's store before heading home.
- He stated he accidentally bumped into the victim who reacted violently, prompting him to punch back in self-defense.
- Petalino alleged the victim drew a knife and chased him, resulting in a struggle for the weapon before he fled.