View full case

PEOPLE v. RICARDO SAN GABRIEL Y ORTIZ

FACTS:

Ricardo O. San Gabriel was charged with murder for allegedly assaulting and stabbing to death Jaime A. Tonog on November 26, 1989. The fight between Tonog and the accused, together with "Ramon Doe," initially broke up when onlookers intervened. However, the accused and Ramon returned with bladed weapons, approached Tonog, and simultaneously stabbed him in the stomach and back. Tonog was brought to the hospital but was pronounced dead on arrival.

Dr. Marcial G. Cenido, the Medico-Legal Officer, autopsied the victim's body and confirmed that the stab wounds were fatal.

The accused claimed that Tonog was drunk and initiated the fight by attempting to box him. He further alleged that Tonog went on to provoke Ramon and another person named "Mando" before getting stabbed.

During the trial, the prosecution presented witnesses Brenda Gonzales and Pio Ochobillo who testified in a direct and candid manner. The trial court found their testimonies credible and discredited the accused's version of events. The accused was convicted of murder and was sentenced to life imprisonment and a fine.

On appeal, the accused argued that the trial court erred in giving credence to the testimonies of the prosecution witnesses, finding the killing to be attended with evident premeditation, ruling that he committed treachery, and convicting him of murder.

The appellate court affirmed the conviction, stating that the trial court's findings of fact are entitled to great respect unless there is an abuse of discretion. The court found the prosecution witnesses' testimonies credible and rejected the accused's assertions.

The accused also failed to provide any information regarding the person and circumstances of "Mando," whom he claims stabbed the victim. The accused's failure to present witnesses to support his claim raises doubts about the existence of "Mando."

The accused also argued that Gonzales arrived at the crime scene after the victim was taken to the hospital and that she even inquired from him about the incident. However, this claim contradicts the accused's earlier assertion that Gonzales had a grudge against him.

Overall, the appellate court upheld the trial court's factual findings and affirmed the accused's conviction for murder.

ISSUES:

  1. Did the trial court err in giving credence to the testimonies of prosecution witnesses Brenda Gonzales and Pio Ochobillo, while discrediting the testimony of the accused?

  2. Was the killing of Jaime Tonog attended with evident premeditation?

  3. Did the attack on Jaime Tonog involve treachery, qualifying the crime as murder?

  4. Should the accused be convicted of murder based on the circumstances presented in the case?

RULING:

  1. The Supreme Court found no error in the trial court's decision to credit the testimonies of Brenda Gonzales and Pio Ochobillo over that of the accused. The prosecution witnesses testified in a direct and candid manner, and no credible motive was presented that would lead them to testify falsely against the accused.

  2. The Supreme Court ruled against the presence of evident premeditation. The evidence suggested that the accused returned shortly after a confrontation, indicating a lack of sufficient time to coolly meditate on their actions.

  3. Treachery was affirmed as present. The attack was carried out suddenly and simultaneously by the assailants, with the victim given no opportunity to defend himself which ensured execution without risk to the attackers.

  4. The Court affirmed the conviction of the accused for murder, despite the absence of evident premeditation, as the presence of treachery qualified the killing as murder. The original sentencing to life imprisonment was modified to reclusion perpetua, and the indemnity awarded to the heirs of the victim was increased.

PRINCIPLES:

  • Treachery is present when the offenders employ means that ensure the execution of the crime without risk to themselves, catching the victim off guard and unable to defend.

  • Evident premeditation requires that the perpetrator reflect upon the criminal act beforehand, with evidence showing enough time was provided for such meditation.

  • Credibility of witnesses can be judged based on directness, candor in testimony, and lack of credible shown motive for falsifying testimony.

  • Testimony that provides detailed, consistent accounts holds more weight against evidence offering contradicting and unsupported counter-narratives.

  • Discrepancies in testimonies that are minor and do not impact the credibility of witnesses do not necessarily undermine their testimonies.

  • Entries in official records, such as police blotters, are prima facie evidence, but not conclusive and can be incomplete or inaccurate. They must be corroborated by detailed and reliable testimony in court.