Case Summary (G.R. No. 120135)
Facts of the Case
On December 18, 1989, in Pasig, Metro Manila, during the evening hours, Villegas allegedly approached the victim from behind and stabbed him with a hunting knife, resulting in fatal injuries. The autopsy conducted by Dr. Dario Gajardo confirmed the cause of death as cardio-respiratory arrest due to stab wounds. Eyewitness Lorenzo Marcelo testified that he observed the attack and provided key details regarding the incident, while Eleuteria de Guzman, the victim's mother, also testified about the financial impact of her son's death.
Proceedings and Developments
Following the incident, an Order of Arrest was issued on May 9, 1990, but Villegas evaded arrest for several months until he was detained on August 2, 1993, for another offense. Upon arraignment on September 22, 1993, Villegas pleaded not guilty. The prosecution presented three witnesses against him, with Marcelo's testimony being pivotal in establishing the timeline and details of the murder.
Accused's Defense
Villegas raised an alibi as his defense, claiming he was operating his tricycle at the time of the incident and was unaware of the stabbing until after it occurred. His witness, Adelo Tena, corroborated his alibi, stating that both were occupied with their respective activities during the time of the crime.
Trial Court's Findings
The trial court ultimately credited the testimony of the prosecution’s eyewitness, finding that Villegas’s actions constituted treachery, as the attack was sudden and unprovoked. The Court highlighted that Villegas's flight from justice was indicative of guilt, as he had vanished following the incident.
Appellate Review
In the appeal, Villegas contended that the trial court erred in favoring the testimony of the eyewitness and misapplying the criterion of treachery. He argued inconsistencies in Marcelo's statements undermined his credibility. The appellate court maintained that the evaluation of witness credibility primarily lies with the trial court, which had the advantage of observing the witnesses directly.
Court's Decision on Evidence and Credibility
The appellate court reviewed the evidence, noting that minor inconsistencies in Marcelo’s testimony did not detract from the reliability of his account. It reaffirmed that inconsistencies often do not compromise credibility and, instead, could serve as indicators of truthfulness. The court rejected Villegas's claims of treachery not being present, stating that treachery was evident due to the nature of the attack.
Conclusion and Ruling
The court dismissed the appeal, thus affirming the trial court's original decision. Villeg
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Case Overview
- The case involves Marcos Villegas, the accused-appellant, who sought to reverse the Regional Trial Court (RTC) of Pasig's decision finding him guilty of murder and sentencing him to reclusion perpetua.
- The RTC also ordered him to indemnify the victim's heirs, reimburse funeral expenses, and pay the costs of the case.
- The information filed against Villegas accused him of stabbing Lauro de Guzman with a hunting knife on December 18, 1989, in Pasig, Metro Manila.
Procedural History
- The criminal case was archived after Villegas evaded arrest following the order issued on May 9, 1990.
- He was arrested later on August 2, 1993, for a separate charge, leading to his arraignment on September 22, 1993, where he pleaded not guilty.
- The prosecution presented three key witnesses: Lorenzo Marcelo (eyewitness), Eleuteria de Guzman (the victim's mother), and Dr. Dario Gajardo (the medico-legal officer).
Prosecution's Evidence
- Eyewitness Account:
- Lorenzo Marcelo testified that he saw Villegas stab de Guzman from behind as they walked home from a store.
- Marcelo described the scene, stating it was dark in the alley and well-lit where the incident occurred.
- Autopsy Findings:
- Dr. Gajardo conducted the autopsy and reported that de Guzman died from stab wounds, with specific details on the nature and location of the wounds.
- Victim's Background:
- Eleuteria de Guzman provided i