People vs. Marzan

G.R. No. 189294 (February 21, 2011)

Facts:

On May 10, 1996, Herminiano Marzan y Olonan was accused of the murder of eight-year-old Joseph Sarmiento in the Regional Trial Court (RTC) of Tacurong, Sultan Kudarat. The Information charged that on February 22, 1996, in Sitio Valdez, Barangay Romualdez, the accused, with intent to kill and with evident premeditation and treachery, attacked, assaulted, and strangled the victim, resulting in his instantaneous death.

On the afternoon of February 22, 1996, Samuel Basalio, a farmer, observed the appellant and the victim walking towards a creek. Approximately 20 minutes later, Basalio saw the appellant walking alone from the creek. The following morning, the victim's mother reported him missing, prompting local officials to search for him. The appellant was found at Makar Port but fled upon seeing the authorities, leading to his capture by the maritime police. Meanwhile, the victim's body was discovered in the creek, and a postmortem examination confirmed death by strangulation.

The appellant denied the charges, admitting he was with the victim earlier that day but claimed he allowed the boy to go to the barangay proper at around 4:00 p.m. The RTC convicted the appellant of murder based on circumstantial evidence, including his presence with the victim, his flight from authorities, and the discovery of the victim's body in the same area they were last seen together. The RTC sentenced him to reclusion perpetua and ordered him to pay civil indemnity and damages.

The Court of Appeals affirmed the RTC's decision but modified the civil liability, awarding additional moral and temperate damages. The case was subsequently brought to the Supreme Court for final review.

Legal Issues:

1. Whether the circumstantial evidence presented was sufficient to establish the guilt of the appellant beyond a reasonable doubt.
2. Whether the qualifying circumstance of treachery was properly appreciated by the lower courts.
3. The appropriateness of the civil liabilities imposed on the appellant.

Arguments:

For the Prosecution:

• The prosecution presented eight pieces of circumstantial evidence linking the appellant to the crime, including his last known presence with the victim, his flight from authorities, and the discovery of the victim's body in the creek.
• The prosecution argued that the evidence constituted an unbroken chain leading to the conclusion of the appellant's guilt.
• The prosecution maintained that the qualifying circumstance of treachery was present due to the victim's age and inability to defend himself.

For the Defense:

• The appellant's defense was primarily based on denial, asserting that he allowed the victim to leave for the barangay proper and had no involvement in the crime.
• The defense argued that the circumstantial evidence was insufficient to establish guilt beyond a reasonable doubt, emphasizing the lack of direct evidence linking the appellant to the act of murder.

Court's Decision and Legal Reasoning:

The Supreme Court affirmed the conviction of the appellant, agreeing with the RTC and the Court of Appeals that the circumstantial evidence presented constituted a strong basis for the conviction. The Court noted that the evidence formed an unbroken chain leading to the conclusion that the appellant was the perpetrator of the crime. The Court emphasized that the defense of denial was inherently weak and could not outweigh the credible testimonies of witnesses who placed the appellant at the scene of the crime.

The Court also upheld the appreciation of treachery as a qualifying circumstance, noting that the victim's tender age rendered him defenseless against the attack. The Court found that the penalty of reclusion perpetua was appropriate given the absence of aggravating or mitigating circumstances.

Additionally, the Court modified the civil liabilities imposed on the appellant, ordering him to pay exemplary damages due to the presence of treachery in the commission of the crime.

Significant Legal Principles Established:

• Circumstantial evidence can be sufficient for conviction if it forms an unbroken chain leading to the conclusion of guilt.
• Denial as a defense is weak and requires corroborating evidence to be credible.
• The presence of treachery, especially against a victim of tender age, can significantly affect the appreciation of the crime and the penalties imposed.