FACTS:

Accused-appellant Warren M. Ivero (Ivero) was charged with the crime of Murder for stabbing his live-in partner, Shiela Cumahig, resulting in her death. A neighbor testified that on the night of the incident, he heard the victim shouting for help and witnessed her crawling on the ground, covered in blood. The victim was brought to the hospital where she passed away, and she identified Ivero as her attacker.

Another witness, the victim's aunt, testified that she allowed the victim and her children to temporarily stay in her house after the victim asked for help. She received a call from the victim, saying that Ivero was at the house, and later received another call informing her that the victim had been stabbed. When she returned to the house, she found a blood-stained knife and her niece's children crying.

Two other witnesses testified that they encountered Ivero shortly after the incident and apprehended him with the assistance of other individuals.

Ivero claimed that he was innocent and that he had been framed by the victim's aunt, who allegedly took the victim and her children without his consent. He claimed that upon arriving at the aunt's house, he found the victim injured, and she told him that another person had stabbed her.

The case involves the conviction of Warren Ivero for the crime of murder. The factual background of the case includes an incident wherein Ivero's wife, Shiela Cumahig, was stabbed and injured by Jovy, prompting Ivero to chase after Jovy while shouting for help. During the pursuit, Ivero was attacked by Malate and Dullavin, who poked him with a swiss knife, took his money and cellphone, and beat him.

Ivero was ultimately found guilty by the Regional Trial Court (RTC) and sentenced to reclusion perpetua, which was affirmed by the Court of Appeals (CA) with modifications. Ivero appealed to the Supreme Court, arguing that the CA's decision was contrary to facts, laws, and applicable jurisprudence.

However, the Supreme Court ruled that the appeal had no merit and upheld the factual findings of the trial court and the CA, emphasizing the weight and respect given to the credibility of witnesses as determined by the trial court's observation of their demeanor and behavior.

ISSUES:

1. Whether the findings of the trial court regarding the credibility of the prosecution witnesses should be respected.

2. Whether the elements of murder were established in this case.

3. Whether the dying declaration of the victim is admissible as evidence.

4. Whether or not the qualifying circumstance of treachery or alevosia can be considered in the killing of the victim.

5. Whether or not the requisites for treachery are present in the killing of the victim.

6. Whether the attack on the victim could be considered treacherous.

7. Whether the victim and the accused were married.

8. Whether the defense of denial and frame-up should be accepted.

RULING:

1. The findings of the trial court regarding the credibility of witnesses carry great weight and will not be overturned unless there was a misapplication or misunderstanding of facts. The trial court is in the best position to assess the sincerity and spontaneity of witnesses through their observation of demeanor and behavior. This rule applies even more strictly if the findings are affirmed by the Court of Appeals.

2. The first element of murder was established through the testimony of the doctor who conducted the post-mortem examination. The second element, that the accused killed the victim, was proven through the dying declaration of the victim. The dying declaration is considered evidence of the highest order and is entitled to utmost credence, especially if it was made under the consciousness of impending death. The third and fourth elements, the presence of qualifying circumstances and the exclusion of parricide or infanticide, were not discussed in this excerpt.

3. The dying declaration of the victim is admissible as evidence if the following requisites are met: First, it should concern the cause and surrounding circumstances of the declarant's death. Second, it should be made under the consciousness of an impending death. Third, the declarant should be competent as a witness. Fourth, it should be offered in a criminal case for homicide, murder, or parricide in which the declarant is the victim. In this case, all the requisites were satisfied.

4. Yes, the qualifying circumstance of treachery or alevosia can be considered in the killing of the victim.

5. Yes, the requisites for treachery are present in the killing of the victim.

6. Yes, the attack on the victim is considered treacherous because it was unexpected and the victim was unarmed and unable to defend herself.

7. No, the victim and the accused were not married, as established by the evidence presented.

8. No, the defense of denial and frame-up was rejected because the accused's testimony was uncorroborated and his behavior after the incident was inconsistent with that of an innocent person.

PRINCIPLES:

• Trial courts are in the best position to assess the credibility of witnesses.

• The elements of murder are the killing of a person, the accused as the perpetrator, the presence of qualifying circumstances, and the exclusion of parricide or infanticide.

• Dying declarations are admissible as evidence if they fulfill certain requisites: concerning the cause and surrounding circumstances of the declarant's death, made under the consciousness of an impending death, the declarant being competent as a witness, and offered in a criminal case for homicide, murder, or parricide where the declarant is the victim.

• In order for the qualifying circumstance of treachery to be appreciated, the following requisites must be shown: (1) the employment of means, method, or manner of execution would ensure the safety of the malefactor from the defensive or retaliatory acts of the victim, no opportunity being given to the latter to defend himself or to retaliate, and (2) the means, method, or manner of execution was deliberately or consciously adopted by the offender.

• The swift and sudden stabbing done by the offender in this case left the victim with no sufficient means to put up a defense, rendering her helpless and unable to retaliate.

• Treachery can be present even in a frontal attack if it is unexpected and the victim is unable to defend themselves.

• The nomenclature used by the State in describing the crime committed should be correct.

• Self-serving uncorroborated testimonies may be rejected by the court.

• Inconsistent behavior after an incident may negate a defense of denial and frame-up.