People vs. Salafranca

G.R. No. 173476 (February 22, 2012)

Facts:

Rodrigo Salafranca y Bello was charged with the murder of Johnny Bolanon, who was fatally stabbed near the Del Pan Sports Complex in Binondo, Manila, on July 31, 1993. After the stabbing, Bolanon managed to walk to his uncle Rodolfo B. EstaAo's house to seek help. During the taxi ride to the Philippine General Hospital, Bolanon identified Salafranca as his assailant. Despite receiving medical attention, Bolanon succumbed to his injuries shortly after arriving at the hospital.

Salafranca fled the scene immediately after the incident and evaded arrest for nearly a decade until he was apprehended on April 23, 2003. The Regional Trial Court (RTC) found Salafranca guilty of murder on September 23, 2004, citing the testimonies of witnesses, including EstaAo and a minor named Augusto Mendoza, who witnessed the stabbing. The RTC noted the presence of treachery in the manner of the attack, as Salafranca had attacked Bolanon from behind, preventing him from defending himself.

The RTC sentenced Salafranca to reclusion perpetua and ordered him to pay the heirs of Bolanon P50,000.00 as death indemnity. Salafranca appealed the decision, challenging the credibility of the witnesses and the sufficiency of the evidence against him.

Legal Issues:

1. Whether the testimonies of the witnesses, particularly the dying declaration of Bolanon, were admissible and credible.
2. Whether the evidence presented was sufficient to establish Salafranca's guilt beyond a reasonable doubt.
3. Whether the RTC and the Court of Appeals (CA) correctly appreciated the presence of treachery as an aggravating circumstance in the commission of the crime.
4. Whether the heirs of Bolanon were entitled to additional civil damages beyond the death indemnity.

Arguments:

• For the Prosecution:

  • The prosecution argued that Bolanon's statement identifying Salafranca as his assailant constituted a dying declaration, which is admissible under the Rules of Court. They emphasized the credibility of the witnesses, particularly EstaAo and Mendoza, who provided consistent and corroborative accounts of the incident.
  • The prosecution maintained that Salafranca's flight after the incident indicated consciousness of guilt and that the manner of the attack demonstrated treachery.

• For the Defense:

  • Salafranca contended that the testimonies of the witnesses were unreliable and inconsistent. He argued that the prosecution failed to prove his guilt beyond a reasonable doubt and that his alibi placed him at home during the time of the incident.
  • The defense also challenged the characterization of the attack as treacherous, asserting that Bolanon had the opportunity to defend himself.

Court's Decision and Legal Reasoning:

The Supreme Court affirmed the decisions of the RTC and CA, finding that the testimonies of Mendoza and EstaAo were credible and reliable. The Court held that Bolanon's statement to EstaAo, made shortly after the stabbing, met the criteria for both a dying declaration and res gestae, thus admissible as evidence despite being hearsay.

The Court reiterated the requisites for a dying declaration, confirming that Bolanon was conscious of his impending death and competent to testify. The Court also found that the elements of res gestae were satisfied, as Bolanon's statement was made spontaneously in reaction to the startling event of his stabbing.

Regarding the issue of treachery, the Court agreed with the lower courts that Salafranca's method of attack—striking Bolanon from behind—prevented any possibility of defense, thus qualifying the crime as murder with treachery.

On the matter of civil damages, the Court modified the awards, granting additional moral damages of P50,000.00, temperate damages of P25,000.00, and exemplary damages of P30,000.00 to the heirs of Bolanon, recognizing their right to compensation for the emotional suffering caused by the violent death of their family member.

Significant Legal Principles Established:

1. Dying Declaration and Res Gestae: The case underscores the admissibility of dying declarations and statements made as part of res gestae, which are exceptions to the hearsay rule, provided certain conditions are met.
2. Treachery as an Aggravating Circumstance: The decision clarifies that treachery can be established through the manner of attack, particularly when the assailant employs means that ensure the success of the attack without risk to themselves.
3. Civil Damages in Homicide Cases: The ruling emphasizes the entitlement of victims' heirs to various forms of damages, including moral and exemplary damages, in addition to death indemnity, reflecting the emotional and psychological impact of violent crimes on the victims' families.