PEOPLE v. DANILO CONDE Y MINA

FACTS:

This case involves the appeal of Danilo Conde y Mina (accused-appellant) from the Decision of the Regional Trial Court (RTC) finding him guilty beyond reasonable doubt of Murder under Article 248 of the Revised Penal Code (RPC). The case stemmed from an Information charging accused-appellant with Murder for killing Reynaldo Adlawany Antonio.

The prosecution presented three eyewitnesses who testified that on the night of February 24, 2013, they were drinking together with accused-appellant and Reynaldo when accused-appellant suddenly and without provocation stabbed Reynaldo in the chest. One of the witnesses also stated that accused-appellant stabbed him when he asked why he stabbed Reynaldo. Reynaldo was brought to the hospital but was already dead.

Accused-appellant denied the charge, claiming that he fell asleep at a waiting shed after buying "pulutan" and was awakened by the witnesses who told him that he stabbed Reynaldo.

The RTC found accused-appellant guilty of Murder, while the CA affirmed the decision with modification, increasing the awards of civil indemnity and moral damages. Accused-appellant appealed to the Supreme Court, arguing that the RTC erred in giving weight to the prosecution witnesses' statements and disregarding his defense of denial and alibi.

ISSUES:

  1. Whether the factual findings of the trial court and the appellate court should be accorded great weight and respect.

  2. Whether the elements of Murder are present in this case.

  3. Whether the prosecution witnesses' testimonies are credible.

  4. Whether the defense adequately refuted the statements of the prosecution witnesses.

  5. Whether the defense of denial and alibi should be given weight in law.

  6. Whether the prosecution proved the qualifying circumstance of treachery.

  7. Whether the prosecution established the elements of evident premeditation.

  8. Whether there is an aggravating circumstance of nighttime present in the case.

  9. Whether the proper amounts for civil indemnity, moral damages, and exemplary damages were awarded by the Court.

RULING:

  1. The factual findings of the trial court are entitled to great weight and respect, especially when affirmed by the appellate court. Findings of the trial court that involve the credibility of witnesses are accorded respect, if not finality, when no glaring errors, gross misapprehension of facts, and speculative, arbitrary, and unsupported conclusions can be gleaned from such findings.

  2. The Court affirms accused-appellant's conviction for the crime of Murder. All the elements of Murder are present, including the killing of a person, the accused being the one who killed him, the presence of treachery, and the absence of parricide or infanticide.

  3. The prosecution witnesses positively identified accused-appellant as the person who stabbed the victim. Their testimonies were clear, straightforward, consistent, and unobstructed by any object. There is no evidence to suggest any dubious reason or improper motive for them to falsely testify against accused-appellant. Hence, their testimonies are credible.

  4. The defense failed to adequately refute the statements of the prosecution witnesses. Accused-appellant only offered a weak defense of denial and alibi. This defense did not disprove the prosecution's evidence and failed to show any logical or rational ground why accused-appellant could not have committed the crime.

  5. The defense of denial and alibi should not be given weight in law if not substantiated by clear and convincing evidence. Denial and alibi are weak defenses and should be considered with suspicion and caution as they can easily be fabricated and are inherently unreliable.

  6. The prosecution successfully proved the qualifying circumstance of treachery. Treachery is defined as the swift and unexpected attack on an unarmed victim without provocation. In this case, the accused suddenly stabbed the victim while he was conversing with others, depriving the victim of any chance to defend himself. The accused had the means to commit the crime and intentionally adopted means that ensured the killing of the defenseless victim.

  7. The prosecution failed to establish the elements of evident premeditation. There is no evidence that the accused made a previous decision to commit the crime or that his acts manifestly indicated his determination to kill the victim. There is also no proof of the time when the accused resolved to commit the crime.

  8. The Court ruled that there is no evidence to prove the aggravating circumstance of nighttime. The prosecution failed to establish that the accused-appellant took advantage of the darkness to facilitate the commission of the crime.

  9. The Court affirmed the amounts awarded by the Court of Appeals for civil indemnity, moral damages, and exemplary damages, which is P75,000.00 each. However, it modified the decision by awarding actual damages for funeral expenses in the amount of P30,225.00. The monetary awards shall also earn a legal interest rate of six percent (6%) per annum from the finality of the decision until full payment.

PRINCIPLES:

  • Factual findings of the trial court, especially when affirmed by the appellate court, are accorded great weight and respect unless there are glaring errors, gross misapprehension of facts, and speculative, arbitrary, and unsupported conclusions.

  • The elements of Murder include the killing of a person, the accused being the one who killed him, the presence of qualifying circumstances such as treachery, and the absence of parricide or infanticide.

  • The credibility of witnesses is best assessed by the trial court due to its unique opportunity to observe the witnesses' demeanor, conduct, and attitude under grueling examination.

  • When there is no evidence to show any dubious reason or improper motive for a prosecution witness to falsely testify against an accused, the witness's testimony is worthy of full faith and credit.

  • A weak defense of denial and alibi is insufficient to refute the testimonies of credible prosecution witnesses.

  • Denial and alibi are weak defenses and should be considered with suspicion and caution if not substantiated by clear and convincing evidence.

  • Treachery requires the swift and unexpected attack on an unarmed victim, depriving the victim of any chance to defend himself. The means, methods, or forms of execution must be deliberately adopted by the assailant.

  • Evident premeditation requires a previous decision by the accused to commit the crime, overt acts indicating the accused's determination, and a lapse of time between the decision and the actual execution of the crime.

  • The aggravating circumstances must be proven beyond reasonable doubt by the prosecution.

  • The proper amount for civil indemnity, moral damages, and exemplary damages should be determined based on the circumstances of the case and regardless of the number of qualifying aggravating circumstances present.

  • Actual damages for funeral expenses must be adequately supported by evidence.

  • Monetary awards shall earn a legal interest rate of six percent (6%) per annum from the finality of the decision until full payment.