People vs. Velarde
G.R. No. 97935 (October 23, 1996)
Facts:
On the evening of August 20, 1990, during a town fiesta in Catarman, Northern Samar, Sonny Tonog was fatally stabbed by Joel Aliposa and Crispin Velarde. The incident occurred while Tonog was watching a "twirling roosters game" with his friends, Pedro Jumadiao and Enrique Saludario. Aliposa approached Tonog, wrapped his arm around him, and engaged him in conversation. Velarde stood nearby. Without warning, Aliposa drew a small bolo (depang) and stabbed Tonog twice in the chest. Velarde then followed suit, stabbing Tonog with a fan knife (batangas knife) as Aliposa released his hold on the victim. After the attack, both assailants chased away Tonog's companions.
Following the stabbing, Lt. Isaias Tonog, the victim's cousin and the local police station commander, was alerted and rushed to the scene. He pursued Aliposa and Velarde to the latter's home, where he apprehended them. During the apprehension, weapons used in the attack were recovered. An autopsy revealed that Tonog died from multiple stab wounds, with the cause of death attributed to massive hemorrhage.
Aliposa and Velarde were charged with murder. At trial, the prosecution presented eyewitnesses who testified to the coordinated nature of the attack, while the defense claimed self-defense and presented an alibi.
Legal Issues:
- Whether the testimonies of the prosecution witnesses were credible and sufficient to establish the guilt of the accused beyond a reasonable doubt.
- Whether the defense of self-defense and the alibi presented by Aliposa and Velarde were credible and sufficient to exonerate them from the charges.
- Whether the qualifying circumstance of treachery was present in the commission of the crime.
Arguments:
Prosecution:
- The prosecution argued that the testimonies of eyewitnesses Saludario and Jumadiao were consistent and credible, establishing that both Aliposa and Velarde conspired to attack Tonog. The coordinated nature of the attack indicated a premeditated intent to kill, qualifying the crime as murder with treachery.
- The prosecution also highlighted the forensic evidence from the autopsy, which corroborated the eyewitness accounts regarding the nature and location of the stab wounds.
Defense:
- Aliposa claimed he acted in self-defense, asserting that he was attacked first by Tonog and that he alone inflicted the fatal wounds. He contended that Velarde was not involved in the stabbing.
- Velarde presented an alibi, claiming he was at home watching a movie during the time of the incident. He argued that the prosecution's witnesses were unreliable and that their testimonies were inconsistent.
Court's Decision and Legal Reasoning:
The court affirmed the trial court's decision, finding both Aliposa and Velarde guilty of murder. The court reasoned that the testimonies of the prosecution witnesses were credible and consistent, providing a clear account of the events leading to Tonog's death. The court rejected the defense's claims of self-defense and alibi, noting that the evidence did not support the assertion that Tonog was the aggressor.
The court also found that the attack was executed with treachery, as Aliposa and Velarde approached Tonog without warning and attacked him in a manner that ensured their safety from any potential retaliation. The coordinated nature of the attack demonstrated a unity of purpose and intent to kill.
Significant Legal Principles Established:
- The case reaffirmed the principle that the credibility of eyewitness testimony is crucial in establishing guilt in criminal cases. The court emphasized that minor inconsistencies in witness statements do not necessarily undermine their overall credibility.
- The ruling underscored the importance of the qualifying circumstance of treachery in murder cases, highlighting that an attack executed in a sudden and unexpected manner can elevate the crime from homicide to murder.