Title
People vs. Zulieta
Case
G.R. No. 192183
Decision Date
Nov 11, 2013
Andy Zulieta, alias "Bogarts," convicted of murder for stabbing Armand Labando, Jr. Witness testimony overruled alibi; treachery proven. Penalty: reclusion perpetua with damages.

Case Summary (G.R. No. 6801)

Factual Antecedents

On July 21, 2006, an Information was filed in court charging Zulieta with Murder, alleging that he stabbed Labando in the chest using a Batangas knife, resulting in Labando's immediate death. Zulieta pleaded not guilty during his arraignment on November 3, 2006. The absence of a pre-trial stipulation led to a full trial on the merits.

Summary of Facts

The prosecution's case began with the testimony of SPO1 Apolinario Ubilas, who investigated the stabbing incident. He reported that Labando was declared dead on arrival at the Northern Mindanao Medical Center. The prosecution's key witness was Bryan Pascua, who testified that he witnessed Zulieta stab Labando after an unprovoked approach. Medical evidence from Dr. Francisco Romulo C. Villaflor confirmed a fatal stab wound to Labando's heart. The defense, led by Zulieta and his wife, claimed he was asleep at home during the incident, asserting alibi as their primary defense.

Ruling of the Regional Trial Court

On October 24, 2007, the RTC found Zulieta guilty of Murder with treachery as an aggravating circumstance and sentenced him to reclusion perpetua. They ordered Zulieta to pay the heirs of Labando civil and moral damages amounting to Php100,000 and costs of suit.

Ruling of the Court of Appeals

On August 13, 2009, the CA affirmed the RTC's decision with modifications. It increased the awarded damages to include Php25,000 as exemplary damages, alongside the civil and moral damages previously decreed.

Assignment of Error

Zulieta appealed, asserting that the prosecution failed to prove his guilt beyond a reasonable doubt and argued that even if he had been present at the crime scene, treachery was not established due to a lack of prior warning or provocation.

Our Ruling

The appeal was dismissed as it lacked merit. The Court found Zulieta's alibi to be weak and uncorroborated, while witness Pascua's identification of Zulieta was deemed credible and reliable. Furthermore, the Court affirmed the finding of treachery, highlighting that the attack was sudden and unprovoked, leaving Labando with no opportunity to defend himself.

Credibility and Review of Evidence

The Court acknowledged that factual findings and credibility assessments by the trial court should be afforded respect unless shown to be erroneous. It determined that the trial court thoroughly reviewed the evidence and maintained that Zulieta was responsible for Labando's death.

Penalty and Damages

Under Article 248 of the Revised P

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