## FACTS:
Alejandro Fuentes, Jr. appeals the decision of the Court of Appeals that upheld his conviction for murder. The incident took place during a benefit dance in Tudela, Trento, Agusan del Sur on June 24, 1989, where Fuentes approached Julieto Malaspina and stabbed him in the abdomen with a hunting knife. Malaspina later died from his injuries and before his death, he identified Fuentes as his assailant. The autopsy conducted by Dr. Porfirio L. Salubre confirmed the cause of death as a stab wound. Fuentes argued that his cousin, Zoilo Fuentes, Jr., alias "Jonie," was the perpetrator and that he confessed to the crime after taking refuge in Fuentes' brother's house. Fuentes was convicted of murder with treachery by the Regional Trial Court and the decision was affirmed by the Court of Appeals. Fuentes claims that he was wrongly identified as the killer and objects to being held liable for damages. The court disregarded an alleged inconsistency in the prosecution witnesses' testimonies about the location of the stabbing, emphasizing that three of them positively identified Fuentes as the assailant. Fuentes' claim regarding his cousin's confession was dismissed as hearsay.
## ISSUES:
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Whether the Court of Appeals erred in affirming the conviction of Alejandro Fuentes Jr. for murder.
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Whether the declaration against penal interest attributed to Zoilo Fuentes Jr. is admissible in evidence as an exception to the hearsay rule.
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Whether the court a quo correctly imposed an indeterminate prison term for the offense of murder.
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Whether the award of P8,300.00 as actual damages was valid.
## RULING:
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The Supreme Court affirmed the decision of the Court of Appeals which upheld the conviction of Alejandro Fuentes Jr. for murder. The Court found that the identification of Fuentes as the assailant by three prosecution witnesses was credible and sufficient. These witnesses knew the petitioner well and had no ill motives against him. Additionally, discrepancies in the location of the stab wound were deemed inconsequential as the identification of the petitioner as the perpetrator was clear.
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The Court ruled that the declaration against penal interest made by Zoilo Fuentes Jr. was not admissible as an exception to the hearsay rule. The Court emphasized the need for the declarant to be unavailable for the exception to apply. In this case, Zoilo's mere absence from the jurisdiction did not satisfy the requirement of unavailability. Moreover, the statement's trustworthiness was questioned due to the relational bias and lack of efforts by the defense to present Zoilo as a witness.
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Regarding the imposition of the prison term, the Court corrected the lower courts' sentencing. It held that the proper penalty for murder under Article 248 of the Revised Penal Code, with only the qualifying circumstance of treachery and no other modifying circumstances, was reclusion perpetua.
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The Court invalidated the award of P8,300.00 as actual damages. It was determined that the claim was not substantiated with competent proof. The testimony of the victim's sister alone, without supporting documentary evidence, was insufficient to establish the actual loss.
## PRINCIPLES:
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Positive Identification: Positive and credible identification by witnesses who are familiar with the accused can form a sufficient basis for conviction in criminal cases.
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Admissibility of Declarations Against Penal Interest: A declaration against penal interest may be admissible if the declarant is unavailable, the declaration refers to a fact that the declarant could have known, and there are no circumstances to suspect a motive to falsify.
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Correct Imposition of Penalties: In criminal law, the proper penalty must be imposed based on the applicable statutory provisions, considering the circumstances of the crime.
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Proof of Actual Damages: Actual damages must be proven with a reasonable degree of certainty, supported by credible evidence, typically through documentary proof like receipts. Speculation or mere testimony without corroboration is insufficient.