Title
People vs. Realin
Case
G.R. No. 126051
Decision Date
Jan 21, 1999
A drinking session turned fatal when ARNOLD, after a quarrel, returned to JAMES’s house, struck him with an ax, resulting in his death. Despite ARNOLD’s alibi, eyewitness testimonies led to his conviction for homicide, with reduced penalties due to insufficient evidence of premeditation or treachery.

Case Summary (G.R. No. 126051)

Nature of the Case

The case involves Arnold Realin, who was found guilty of murder by the trial court for the fatal assault of James Leiza using an ax-like instrument. The information was filed on October 31, 1989, and alleged that the murder occurred on June 11, 1988, with charges of treachery and evident premeditation.

Trial Proceedings

The trial court conducted proceedings where both the prosecution and defense presented witnesses. The prosecution's key witnesses, who claimed to witness the attack, included relatives of the victim. The defense presented an alibi stating Arnold was away during the time of the crime. The trial court eventually found Arnold guilty and sentenced him to reclusion perpetua and ordered him to pay damages.

Testimonies and Evidence

  • Prosecution's Account:

    • Witness Angeles dela Cruz described an altercation leading to Arnold attacking James with an ax-like weapon. She observed Arnold while trying to pacify another guest and later saw him strike James.
    • Perlita Candelario corroborated this, noting prior commotion in the gathering and confirming Arnold's actions following their departure.
    • Other witnesses, including Mauro Sison and the Barangay Captain, recounted events leading to the incident and the subsequent investigation by the police.
  • Defense Account:

    • Arnold provided an alibi claiming he was at home the night of the incident and discussed events leading up to his eventual arrest.
    • His witnesses challenged the credibility of the prosecution's narratives, highlighting inconsistencies in the testimonies.

Ruling of the Trial Court

The trial court convicted Arnold on March 26, 1996, citing evident premeditation as a qualifying circumstance. It reasoned that Arnold's return to James's residence after the altercation demonstrated premeditated intent to commit murder.

Appeal and Arguments

In his appeal, Arnold asserted the following:

  1. Insufficient evidence supported his conviction.
  2. The trial court favored the prosecution's witnesses without adequately considering the defense.
  3. Circumstances indicating self-defense or voluntary surrender were overlooked.

Supreme Court's Findings

Upon reviewing the case, the Supreme Court emphasized the credibility of eyewitness accounts, asserting that familial ties to the victim do not inherently undermine a witness's truthfulness. The court recognized the complexities surrounding human behavior during traumatic events and rejected the assertion that the witnesses' delayed reporting of the incident affected their reliability.

Notably, the Supreme Court disagreed with the trial court's classifica

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