People vs. Seguisabal

Treachery qualifies a killing as murder where the attack is deliberate, sudden, and unexpected, rendering the victim unable to defend himself, and the accused consciously adopted the means of attack. The defense of denial and alibi cannot prevail over the positive identification by credible, disinterested eyewitnesses whose testimonies are corroborated, absent any showing of improper motive to falsely testify.

The accused-appellant, Renante Seguisabal y Trasona, was charged with the crime of murder under Article 248 of the Revised Penal Code for the fatal stabbing of Jose Marvin B. Candol on August 17, 2008, in Naga City, Cebu. The victim and his cousins attended a disco event at a barangay basketball court, where the stabbing occurred. The accused was a carpenter employed at Carmen Copper Corporation and was an unfamiliar person to the victim's group prior to the incident.

On August 17, 2008, at around 2:00 a.m., Jose Marvin B. Candol and his cousins—Jose Rolando Candol, Kindred Bartolata, Yulmar, and Gacho—attended a disco event at the basketball court of Barangay Uling, Naga, Cebu City. The cousins formed a circle while dancing, positioned roughly two arms' length from one another. While dancing, Rolando observed that Marvin inadvertently elbowed and stepped on an unfamiliar person, later identified as accused-appellant Renante Seguisabal y Trasona. Rolando and Kindred thereafter noticed that accused-appellant appeared incensed, as he kept nudging and staring at Marvin.

Accused-appellant later positioned himself behind Marvin and suddenly stabbed him from behind, then hastily fled the scene. Mario Martinez, who was on duty as barangay tanod at the time, saw accused-appellant exiting the basketball court with bloodied hands. Martinez immediately reported what he had witnessed to the councilor on the apprehension that someone might have been stabbed at the disco. Later that morning, at 6:00 a.m., Martinez recounted the incident to Barangay Captain Justino Dakay, and the same was entered in the barangay blotter.

Rolando brought Marvin to the South General Hospital in Naga City, but the latter expired. Marvin's Certificate of Death stated the cause of death as "ACUTE MASSIVE BLOOD LOSS, SECONDARY TO STAB WOUND, RIGHT UPPER QUADRANT." PO2 Ken Cabrera of the Naga City Police learned of the stabbing incident in the late afternoon of the same day. Together with several other police officers, he went to Barangay Captain Dakay to identify the perpetrator. Dakay called Martinez, who led them to accused-appellant's house, which was Martinez's neighbor. The team saw accused-appellant in the neighborhood and arrested him after reading his rights. PO2 Cabrera brought accused-appellant to the Naga Police Station, where Rolando and Kindred identified him as the person who stabbed Marvin.

Accused-appellant denied involvement and testified that he was sleeping at home at the time of the stabbing, being too tired after working overtime as a carpenter for Carmen Copper Corporation. He stated that he went to work on August 17, 2008, and was apprehended upon returning home when Martinez pointed at him as the perpetrator. He denied that Martinez was his neighbor but acknowledged knowing him, claiming Martinez had once threatened him with the words "One day I will get even with you" after he refused to bring Martinez's bio-data to his office. The RTC credited the prosecution's eyewitness accounts over the defense of denial and alibi, a finding subsequently affirmed by the CA.

• Sufficiency of Prosecution Evidence: Whether the prosecution proved the guilt of the accused-appellant beyond reasonable doubt, notwithstanding his defense of denial and alibi.
• Qualifying Circumstance of Treachery: Whether treachery was properly appreciated to qualify the killing as murder.
• Propriety of Damages: Whether the awards of civil indemnity, moral damages, exemplary damages, and temperate damages were properly imposed.

• Sufficiency of Prosecution Evidence: Yes. The prosecution established beyond reasonable doubt both the commission of the crime and the identity of the accused as the perpetrator through positive identification by credible, disinterested eyewitnesses corroborated by a barangay tanod, rendering the defense of denial and alibi insufficient.
• Qualifying Circumstance of Treachery: Yes. Treachery was present because the attack was deliberate, sudden, and unexpected—the accused stabbed the victim from behind while the latter was obliviously dancing, satisfying both elements of treachery.
• Propriety of Damages: Yes. The awards of P75,000.00 each for civil indemnity, moral damages, and exemplary damages were sustained pursuant to People vs. Jugueta, and temperate damages of P50,000.00 were additionally awarded in lieu of unproven actual damages, with 6% per annum interest on all monetary awards from date of finality until fully paid.

• Sufficiency of Prosecution Evidence: The prosecution's two-fold task is to prove beyond reasonable doubt both the commission of the crime and the identity of the person responsible. These were satisfied: it was undisputed that Marvin died from a single stab wound, and Rolando and Kindred, who were eyewitnesses, positively identified accused-appellant as the offender. Their testimonies were corroborated by Martinez, the barangay tanod on duty, who saw accused-appellant exiting the basketball court with bloodied hands. The defense of denial and alibi was deemed negative, self-serving, and undeserving of weight unless substantiated by clear and convincing proof. For alibi to prosper, the accused must prove both that he was present at another place at the time of the crime and that it was physically impossible for him to be at the scene. Accused-appellant failed on both requisites. Moreover, Rolando and Kindred were disinterested witnesses—cousins of the victim but without any demonstrated motive to falsely testify against accused-appellant. Absent any evidence of improper motive to perjure, the logical conclusion is that none exists, and their testimonies are worthy of full faith and credit.

• Qualifying Circumstance of Treachery: Murder under Article 248 of the Revised Penal Code requires the following elements: (1) a person was killed; (2) the accused killed him or her; (3) the killing was attended by any of the qualifying circumstances mentioned in Article 248; and (4) the killing does not amount to parricide or infanticide. Treachery was appreciated because the manner of attack was deliberate, sudden, and unexpected: accused-appellant positioned himself behind Marvin and stabbed him while the latter was obliviously dancing. This satisfied the two elements of treachery—first, that at the time of the attack, the victim was not in a position to defend himself, and second, that the accused consciously and deliberately adopted the particular means, methods, or forms of attack employed.

• Propriety of Damages: The CA correctly modified the award of exemplary damages by increasing it to P75,000.00, consistent with the Court's pronouncement in People vs. Jugueta. Civil indemnity of P75,000.00 and moral damages of P75,000.00 were likewise sustained. The award of temperate damages of P50,000.00 was deemed proper because neither the RTC nor the CA had awarded actual damages, and while Marvin's untimely death caused pecuniary loss to his heirs, the exact amount was not proved during trial—permitting temperate damages in lieu of actual damages. Interest at the legal rate of 6% per annum was imposed on all damages awarded from the date of finality of the Decision until fully paid.

• Two-fold burden of the prosecution — The prosecution must prove beyond reasonable doubt both (1) the commission of the crime charged and (2) the identity of the person responsible. Even if the commission of the crime is established, there can be no conviction without the identity of the malefactor being clearly ascertained. The Court found both requisites satisfied through eyewitness identification and corroborating testimony.

• Denial and alibi as weak defenses — Denial and alibi are negative, self-serving, and undeserving of weight in law unless substantiated by clear and convincing proof. For alibi to prosper, the accused must prove (a) that he was present at another place at the time of the perpetration of the crime, and (b) that it was physically impossible for him to be at the scene of the crime during its commission. Accused-appellant failed to satisfy either requisite.

• Disinterested witness doctrine — Witnesses without any apparent motive to falsely testify are considered disinterested, and their testimonies are entitled to full faith and credit. Absent any evidence showing a reason or motive for prosecution witnesses to perjure their testimonies, the logical conclusion is that no improper motive exists. Rolando and Kindred, as cousins of the victim who had no prior acquaintance with accused-appellant, were treated as disinterested witnesses.

• Elements of treachery — Treachery requires (1) that at the time of the attack, the victim was not in a position to defend himself, and (2) that the accused consciously and deliberately adopted the particular means, methods, or forms of attack employed. Both elements were satisfied where the accused stabbed the victim from behind while the victim was dancing and oblivious to the threat.

• Elements of murder under Article 248, RPC — Murder requires (1) a person was killed; (2) the accused killed him or her; (3) the killing was attended by any of the qualifying circumstances mentioned in Article 248; and (4) the killing does not amount to parricide or infanticide. All four elements were found present.

• "The task of the prosecution is always two-fold, that is, (1) to prove beyond reasonable doubt the commission of the crime charged; and (2) to establish with the same quantum of proof the identity of the person or persons responsible therefor, because, even if the commission of the crime is a given, there can be no conviction without the identity of the malefactor being likewise clearly ascertained." — This passage articulates the foundational standard governing the prosecution's burden in criminal cases, framing the analytical structure used to assess sufficiency of evidence.

• "Unless substantiated by clear and convincing proof, denial and alibi is negative, self-serving and undeserving of any weight in law." — This is the canonical formulation of the rule on the weakness of denial and alibi as defenses, frequently cited in Philippine criminal jurisprudence.

• "Absent any evidence showing a reason or motive for the prosecution witnesses to perjure their testimonies, the logical conclusion is that no improper motive exists, and that their testimonies are worthy of full faith and credit." — This passage states the doctrine on the presumption of credibility accorded to witnesses absent any showing of improper motive, a principle central to the assessment of witness credibility.

• People vs. Sota, G.R. No. 203121, November 29, 2017 — Cited for the two-fold burden of the prosecution to prove both the commission of the crime and the identity of the perpetrator.
• People vs. Narciso, 440 Phil. 964 (2002) — Cited for the proposition that denial and alibi, unsubstantiated by clear and convincing proof, are negative, self-serving, and undeserving of weight in law.
• People vs. Macaranas, 811 Phil. 610 (2017) — Cited for the two requisites for the defense of alibi to prosper: presence at another place and physical impossibility of being at the crime scene.
• People vs. Inggo, 452 Phil. 678 (2003) — Cited for the doctrine that absent evidence of improper motive to perjure, prosecution witnesses' testimonies are worthy of full faith and credit.
• People vs. Albino, G.R. No. 229928, July 22, 2019 — Cited for the four elements of murder under Article 248 of the Revised Penal Code.
• People vs. Jugueta, 783 Phil. 806 (2016) — Cited as the controlling precedent for the proper amounts of civil indemnity (P75,000.00), moral damages (P75,000.00), and exemplary damages (P75,000.00) in murder cases.
• People vs. Gunda, 726 Phil. 289 (2014) — Cited for the award of temperate damages of P50,000.00 where actual damages were not proved but pecuniary loss was established.

• Article 248, Revised Penal Code — Defines and penalizes murder, enumerating the qualifying circumstances including treachery, taking advantage of superior strength, with the aid of armed men, or employing means to weaken the defense or to insure impunity. The provision was applied to qualify the killing as murder on the basis of treachery, imposing the penalty of reclusion perpetua.

Caguioa, Carandang, Zalameda, and Gaerlan, JJ., concurred.