Case Summary (G.R. No. 233479)
Petitioner
People of the Philippines
Respondent
Rodrigo Salafranca y Bello
Key Dates
• July 31, 1993 – Stabbing incident
• September 23, 2004 – RTC conviction (Manila, Branch 18)
• November 24, 2005 – CA decision affirming conviction
• February 22, 2012 – Supreme Court decision
Applicable Law
• 1987 Philippine Constitution
• Revised Penal Code, Article 248 (as amended by Republic Act No. 7659) and Article 63
• Rules on Evidence (dying declaration, res gestae exceptions)
• Civil Code (Articles 2206, 2217–2219, 2229–2230)
Facts of the Offense
Shortly after midnight on July 31, 1993, Salafranca stabbed Bolanon near the Del Pan Sports Complex in Binondo. Despite his injury, Bolanon walked to his uncle’s home, who transported him by taxi to the Philippine General Hospital. En route, Bolanon identified Salafranca as his assailant. He died at 2:30 a.m. on the same day. Mendoza, a 13-year-old bystander, witnessed the attack.
Procedural History
Salafranca fled after the stabbing and remained at large until his arrest on April 23, 2003. He was tried for murder before the RTC, which convicted him. The CA affirmed the conviction on November 24, 2005. Salafranca appealed to the Supreme Court.
Trial Court Decision
The RTC found that:
• Salafranca delivered two fatal blows while holding Bolanon by the neck, preventing any defense.
• Mendoza’s eyewitness testimony and Bolanon’s ante-mortem identification to his uncle were credible.
• Treachery attended the killing.
• Salafranca’s flight and inconsistent alibi further supported guilt.
He was sentenced to reclusion perpetua, credited for time served, and ordered to pay P50,000 as death indemnity.
Appellate Court Affirmation
The CA upheld the RTC’s findings, stressing the dying declaration and Mendoza’s positive identification. It rejected the alibi and held that the unexplained flight was highly indicative of guilt.
Standard of Review on Witness Credibility
The Supreme Court emphasized that credibility assessments by the RTC are entitled to great weight. Absent clear misappreciation or omission of evidence, neither the CA nor the Supreme Court may disturb such findings.
Admissibility of Victim’s Ante-Mortem Statement
Bolanon’s identification of his assailant was admissible both as a dying declaration and as part of the res gestae. The requirements were satisfied:
• It concerned the cause and circumstances of death.
• Bolanon was conscious of imminent death (severe chest wound and labored breathing).
• He was competent to testify had he survived.
• Offered in a murder prosecution.
Application of Dying Declaration and Res Gestae Exceptions
The declaration was made within three hours of the stabbing during transport to the hospital. It was spontaneous, contemporaneous with the startling event, and could not have been contrived.
Treachery Qualification
Mendoza’s unchallenged account—attack from behind, neck encirclement, unexpected blows—met the defin
Case Syllabus (G.R. No. 233479)
Facts of the Case
- In the early hours of July 31, 1993, Johnny Bolanon was fatally stabbed near the Del Pan Sports Complex in Binondo, Manila.
- After the assault, Bolanon managed to walk to his uncle Rodolfo B. Estaño’s house to seek help.
- Estaño immediately transported Bolanon by taxicab to the Philippine General Hospital.
- En route, Bolanon identified Rodrigo Salafranca y Bello as his attacker.
- Despite medical attention, Bolanon succumbed to his injuries at 2:30 a.m.
- A lone eyewitness, 13-year-old Augusto Mendoza, witnessed the stabbing and later testified.
Flight and Arrest of the Accused
- Rodrigo Salafranca fled the scene immediately and abandoned his residence the following day.
- He remained at large for nearly eight years, residing in Bataan and evading arrest despite a warrant.
- On April 23, 2003, Salafranca was apprehended and detained at the Manila City Jail.
Regional Trial Court Decision
- On September 23, 2004, the RTC (Branch 18, Manila) convicted Salafranca of murder under Article 248 (as amended by R.A. 7659) in relation to Article 63 of the Revised Penal Code.
- Key findings:
- Positive identification by Mendoza.
- Corroboration by Estaño’s testimony, including Bolanon’s ante-mortem declaration.
- Presence of treachery: Salafranca attacked from behind, encircled the victim’s neck with his left arm, and delivered two stabbing blows, leaving no chance for defense.
- Conscious flight and inconsistent alibi undermined the accused’s credibility.
- Sentence imposed: reclusion perpetua, credit for preventive