People v. Alcartado

G.R. No. 119070 (August 30, 1996)

Facts:

The case revolves around the tragic death of Digna Guillermo, who was stabbed multiple times by her common-law husband, Carlito Alcartado, in the early hours of February 16, 1993. The incident occurred at the residence of Virgilio Alcartado, a cousin of the accused, in Danglas, Abra. Virgilio testified that he was awakened by Digna's cries for help and witnessed Carlito attacking her with a bolo. Despite Virgilio's attempts to intervene, Carlito continued the assault until he was eventually subdued, and the bolo was recovered by Virgilio. Digna was rushed to the hospital but was declared dead on arrival. An autopsy revealed multiple stab wounds, leading to her death from hypovolemic shock.

Carlito was charged with murder, and the Regional Trial Court found him guilty, imposing a sentence of reclusion perpetua. The court based its decision on the presence of treachery, evident premeditation, and abuse of superior strength as aggravating circumstances, although the latter was not included in the information.

Legal Issues:

1. Whether the evidence presented justified the conviction of Carlito Alcartado for murder.
2. If so, what specific crime should he be held accountable for, considering the circumstances surrounding the incident.

Arguments:

• Prosecution's Argument: The prosecution relied heavily on the eyewitness testimony of Virgilio Alcartado, asserting that the brutal nature of the attack, coupled with the circumstances of treachery and evident premeditation, warranted a murder conviction. They argued that the attack was deliberate and planned, as Carlito had attempted to persuade Digna's mother to sell her property prior to the incident.

• Defense's Argument: Carlito's defense challenged the credibility of Virgilio, claiming that he had a motive to fabricate his testimony due to personal grievances. The defense also argued that the absence of corroborative testimony from Carlito's children, who were present during the incident, indicated suppression of evidence. They contended that the prosecution failed to prove the qualifying circumstances of treachery and evident premeditation, suggesting that the crime should be classified as homicide instead of murder.

Court's Decision and Legal Reasoning:

The Supreme Court reviewed the trial court's findings and ultimately modified the conviction. The Court upheld the credibility of Virgilio's testimony, emphasizing that the trial judge, who observed the witness's demeanor, was in a better position to assess credibility than an appellate court. The Court found no compelling reason to discredit Virgilio's account, noting that nervousness in such a traumatic situation was expected.

However, the Court disagreed with the trial court's classification of the crime as murder. It ruled that treachery could not be established since the witness did not observe the initial moments of the attack, which is essential to proving treachery. The Court also found that evident premeditation was not sufficiently proven, as the circumstances leading to the attack did not indicate deliberate planning.

The Court acknowledged the presence of the aggravating circumstance of abuse of superior strength, given that Carlito attacked an unarmed and defenseless woman. However, since this circumstance was not alleged in the information, it could only be treated as a generic aggravating circumstance. Consequently, the Court reclassified the crime as homicide, imposing a sentence of 12 to 20 years of reclusion temporal and ordering indemnification for the victim's heirs.

Significant Legal Principles Established:

1. Credibility of Witnesses: The trial court's assessment of witness credibility is given great weight on appeal, especially when the judge has observed the witness's demeanor during testimony.
2. Treachery and Premeditation: Both must be proven beyond reasonable doubt; mere suppositions are insufficient to establish these qualifying circumstances.
3. Generic Aggravating Circumstances: If not alleged in the information, certain aggravating circumstances can still be considered but will affect the classification of the crime and the corresponding penalty.