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PEOPLE v. JENNY LIKIRAN

FACTS:

Jenny Likiran was convicted of Murder by the RTC for the death of Rolando Sareno, Sr. The incident took place during a dance in Barangay Bugca-on. The accused-appellant's brother, Jerome Likiran, punched a witness during the dance and then shot Sareno multiple times. The accused-appellant then stabbed Sareno in the back. Sareno died from the gunshot wounds and stab wound. The accused-appellant denied involvement, claiming they stayed inside the dance hall and only heard the gunshots. The RTC found the accused-appellant guilty based on the positive identification by a witness. The CA affirmed the RTC but disagreed with the finding of conspiracy. The accused-appellant argued that his guilt was not proven beyond reasonable doubt. The Supreme Court upheld the findings, emphasizing the witness's positive identification as sufficient evidence. The Court rejected the accused-appellant's argument that the witness could not see the assailant and stated that there was no evidence of poor lighting in the crime scene. The Court also emphasized the weight of positive identification over alibi and denial.

ISSUES:

  1. Whether the identity of Jenny Likiran as the perpetrator of the crime was sufficiently established.

  2. Whether the killing of Rolando Sareno, Sr. was attended by treachery, qualifying the crime to murder.

  3. Whether the death of Sareno was the immediate result of the stab wound inflicted by the accused-appellant, Jenny Likiran.

  4. Whether the Court of Appeals' award of attorney's fees to the victim's heirs was proper.

RULING:

  1. Yes. The Supreme Court affirmed the lower courts' findings that the identity of the accused-appellant was adequately established by the prosecution witness, Celso Dagangon, whose positive identification outweighed the accused-appellant's defense of denial and alibi.

  2. No. The Supreme Court found that treachery was not present as the attack appeared to be a spur-of-the-moment incident and not premeditated. Hence, the conviction for murder was modified to homicide.

  3. Yes. The Court ruled that the stab wound inflicted by the accused-appellant contributed to the victim’s death, making him criminally liable for homicide.

  4. No. The Supreme Court deleted the award of attorney's fees due to the lack of evidence that such fees were actually incurred by the victim's heirs.

PRINCIPLES:

  1. Positive Identification Testimony identifying the accused by a prosecution witness is entitled to greater weight than an alibi or denial.

  2. Treachery To qualify a killing to murder, treachery must be shown to have been deliberately and consciously adopted by the offender.

  3. Natural and Logical Consequence Doctrine An accused can be held liable for the death of the victim if the acts performed by the accused contributed to or accelerated the death of the victim.

  4. Death Certificate A death certificate issued in the regular performance of a municipal health officer's duty is prima facie evidence of the cause of death.

  5. Award of Attorney’s Fees Attorney’s fees need to be supported by evidence that they were actually incurred; otherwise, they must be deleted for lack of factual basis.