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PEOPLE v. REYMAR MASILANG Y LACISTE

FACTS:

The case involves the appeal of accused-appellant Reymar Masilang y Laciste from the decision of the Court of Appeals affirming with modification the decision of the Regional Trial Court (RTC) of Gapan City, Nueva Ecija, which found him guilty of the crime of murder and sentenced him to reclusion perpetua. The case stemmed from the murder of Rose Clarita A. Yuzon on July 26, 2015. The Information charged accused-appellant of attacking and killing Rose by hacking her several times with a bolo while she was blindfolded and unaware of the attack. During pre-trial, the prosecution and defense stipulated on certain facts, including accused-appellant's identity, his previous relationship with the victim, the witnesses, and the authenticity of the death certificate and photos related to the case. The prosecution presented witnesses who testified to the events leading to the murder, while accused-appellant presented his own version of the events and claimed denial and alibi as his defense. Ultimately, accused-appellant was convicted of murder based on the evidence presented by the prosecution.

The appellant, Reymar Masilang, blindfolded his girlfriend, Rose, as a surprise, but she exclaimed "lintik" when the surprise took longer than expected. Appellant walked away to look for his grandfather's tomb. Shortly after, he heard Rose shouting and crying for help. He tried to reach her but was stopped by a man named Marcelo Perez who brought him to Rose's location. Rose was found dead on the floor, and appellant was arrested and taken to the police station.

The Regional Trial Court (RTC) found appellant guilty of murder qualified by treachery, based on the positive testimony of an eyewitness who saw appellant hacking the victim with a bolo. The trial court did not award civil damages to the victim's heirs due to affidavits of desistance submitted by the victim's parents, which waived their claims against appellant.

Appellant appealed the decision, arguing that there was doubt in his identification as the culprit, and that the prosecution failed to prove the qualifying circumstance of treachery. The Court of Appeals affirmed the RTC's decision but modified it by awarding civil, moral, and exemplary damages to the victim's heirs. The Court of Appeals held that the affidavits of desistance had no probative value since the affiants did not appear in court to confirm their execution or receipt of money from appellant.

The case was elevated to the Supreme Court on appeal.

partial_digest = {

'title': 'People of the Philippines v. Gerry Gonzales',

'citation': 'G.R. No. 187241',

'date': 'October 3, 2012',

'court': 'Supreme Court of the Philippines',

'FACTS': "Accused-appellant Gerry Gonzales was convicted of murder by the Regional Trial Court (RTC) and the Court of Appeals (CA). The case arose from an incident wherein the victim, Renato Velasco, was killed inside the cemetery. The identification of Gonzales as the culprit was primarily based on the testimony of prosecution witness Edgardo Gamboa, who witnessed the crime. Gonzales argued that his identification as the culprit was doubtful since it was established solely through Gamboa's testimony, which lacked corroboration. He also claimed that his name and identity as the culprit were not mentioned in Gamboa's affidavit, and Gamboa himself admitted that he did not remember the faces of the people he observed in the cemetery."

}

print(partial_digest['FACTS'])

ISSUES:

  1. Whether or not the Court of Appeals erred in affirming the trial court's decision that accused-appellant is guilty beyond reasonable doubt of the crime of murder despite the identification being based on the lone testimony of a witness and the defense's arguments against his identification.

  2. Whether or not the qualifying circumstance of treachery was proven by the prosecution.

  3. Whether or not the prosecution failed to prove the guilt of the accused-appellant beyond reasonable doubt.

RULING:

  1. The Court held that the identification of the accused-appellant by the witness, Edgardo Gamboa, was credible despite being uncorroborated. The Court emphasized that an accused's conviction does not hinge on the number of witnesses but rather on the credibility and sufficiency of the testimony.

  2. The Court affirmed that the qualifying circumstance of treachery was sufficiently established. The Court noted that the victim was blindfolded and unprepared for the attack, which ensured that she could not defend herself.

  3. The Court found that the prosecution proved the guilt of the accused-appellant beyond reasonable doubt. The prosecution provided adequate evidence to fulfill all elements of murder, including the presence of treachery, and the negative defenses of denial and alibi by the accused were deemed weak and unconvincing.

PRINCIPLES:

  1. Identification of Accused: An accused can be convicted based on the testimony of a single credible witness.

  2. Treachery: Circumstances such as sudden and unexpected attacks on an unprepared, unarmed victim can establish the qualifying circumstance of treachery in murder cases.

  3. Evaluation of Evidence: The assessment of witness credibility and evaluation of facts by the trial court are generally respected on appeal unless there is clear evidence of arbitrary decision-making or oversight of significant facts.

  4. Denial and Alibi: These defenses are weak against positive identification by a credible witness and hold less weight without substantiating evidence.

  5. Non-Flight as Proof of Innocence: Non-flight does not conclusively prove innocence, especially when there is positive identification by a credible witness.

  6. Affidavits of Desistance: Cannot extinguish criminal liability and have no probative value without the presence of affiants as witnesses.

  7. Civil Liability in Crimes: Criminal liability entails civil liability to the heirs of the victim for damages, such as civil indemnity, moral damages, and exemplary damages.