In People v. Colorada, the Supreme Court affirmed the conviction of Edcel Colorada for murder, emphasizing the critical elements of treachery and the reliability of eyewitness testimony. The court underscored that an unexpected attack on a defenseless victim constitutes treachery, a key factor in determining guilt in murder cases. This decision reinforces the importance of credible witness accounts and the stringent standards by which courts evaluate evidence in criminal proceedings, providing a clear example of how these principles are applied in Philippine jurisprudence.

Blind Justice? How Eyewitness Testimony Sealed a Murder Conviction

The case revolves around the death of Genoveva Barraza, a blind and elderly woman, who was fatally attacked with a bolo. The central question was whether the accused, Edcel Colorada, was indeed the perpetrator, and whether the attack qualified as murder due to the presence of treachery and abuse of superior strength. The prosecution presented eyewitness Apolinario Caigoy, who testified that he saw Colorada enter Barraza’s house and attack her. The defense, however, argued that Apolinario’s testimony was unreliable and inconsistent with the accounts of other witnesses. This discrepancy became a focal point in determining the veracity of the claims and the overall guilt of the accused.

The Supreme Court examined the elements necessary to prove murder under Article 248 of the Revised Penal Code (RPC), stating that the prosecution must demonstrate that: (1) the victim was killed; (2) the killing was not infanticide or parricide; (3) the accused killed the victim; and (4) the killing was attended by any of the qualifying circumstances mentioned in Article 248 of the RPC.

Art. 248. Murder. — Any person who, not falling within the provisions of Article 246 shall kill another, shall be guilty of murder and shall be punished by reclusion temporal in its maximum period to death, if committed with any of the following attendant circumstances:

1. With treachery, taking advantage of superior strength, with the aid of armed men, or employing means to weaken the defense or of means or persons to insure or afford impunity.

The Court paid particular attention to the element of treachery, which is defined as the sudden and unexpected attack on an unsuspecting victim, depriving the victim of any chance to defend himself or herself. Given the victim’s blindness and old age, the Court found that she was indeed defenseless, making the attack treacherous.

Accused-appellant questioned the credibility of the testimony of eyewitness Apolinario, contending that it was unlikely that the accused-appellant would challenge the victim considering she could no longer walk and was already blind. He also argued that Apolinario’s answers to the questions asked were irresponsive in many points and that his testimony as to where the victim was when she was allegedly hacked by the accused-appellant is inconsistent with the testimony of the victim’s two sons. He claims that it was impossible for Apolinario to see the hacking incident fifteen (15) meters away when the victim’s son Ernesto, who was only nine (9) arm’s length away, did not witness it.

The Supreme Court, however, rejected these arguments, emphasizing the established legal principle that minor inconsistencies do not necessarily discredit a witness. As the Court noted in People v. Albarido:

the testimonies of prosecution witnesses with respect to minor details do not affect the substance of their declaration nor the validity or weight of their testimony. In fact, these minor inconsistencies enhance the credibility of the witnesses, for they remove any suspicion that their testimonies were rehearsed. (People v. Albarido, 420 Phil. 235, 244-245 (2001))

The Court also highlighted that the position and angle of Apolinario and Ernesto in relation to where the hacking happened were significantly different. Apolinario testified that the chapel where he hid was right across the house where the incident happened, providing him with a clear view of the crime scene. Ernesto, on the other hand, was in his copra kiln located at the back of his house, which in turn is located beside the house where the hacking incident occurred. The court thus upheld the trial court’s assessment of Apolinario’s credibility, as the trial court found no evidence of ill motive on the part of the witnesses that would lead them to falsely testify against the accused.

The defense also attempted to discredit the victim’s dying declaration, arguing that the victim’s blindness made it impossible for her to identify her attacker. The Court acknowledged this point, noting that the prosecution failed to establish the familiarity between the victim and the accused-appellant, making it doubtful that the former could positively identify her assailant. The Court however clarified that, without even taking into account the victim’s dying declaration, the guilt of accused-appellant was still established beyond reasonable doubt. The prosecution presented several witnesses, including an eyewitness, in the person of Apolinario, who positively identified the accused-appellant as the assailant of the victim.

Central to the Court’s decision was the concept of positive identification versus denial. Apolinario categorically identified Colorada as the one who hacked the victim. This positive identification, corroborated by other testimonies and the medical report, outweighed the accused’s denial, which the Court deemed a weak form of defense. As it is often stated in jurisprudence, denial is an inherently weak defense, particularly when it is not substantiated by clear and convincing evidence.

The Court also addressed the appropriate penalty, noting the aggravating circumstance of disregard for the respect due the offended party on account of her age and sex. Although this would have warranted the death penalty, Republic Act No. 9346 prohibits the imposition of the death penalty, leading the Court to impose reclusion perpetua without eligibility for parole.

In terms of damages, the Court modified the award to align with prevailing jurisprudence. The heirs of Genoveva Barraza were awarded P100,000.00 as civil indemnity, P100,000.00 as moral damages, and P100,000.00 as exemplary damages, with all monetary awards earning interest at the legal rate of six percent (6%) per annum from the date of finality of the judgment until fully paid. This adjustment reflects a commitment to ensuring that the victim’s family receives adequate compensation for their loss, aligning with current legal standards.

This case reinforces the importance of eyewitness testimony and the stringent standards by which courts evaluate evidence in criminal proceedings. The decision serves as a reminder of the legal principles that guide the pursuit of justice in the Philippines, particularly in cases involving heinous crimes like murder. By upholding the conviction, the Supreme Court affirmed its commitment to protecting the vulnerable and ensuring that perpetrators are held accountable for their actions.

FAQs

What was the key issue in this case?	The key issue was whether the accused, Edcel Colorada, was guilty beyond reasonable doubt of murdering Genoveva Barraza, considering the eyewitness testimony and the presence of treachery. The Court had to determine the credibility of the witness and whether the attack qualified as murder under the Revised Penal Code.
What is treachery according to the Supreme Court?	Treachery is defined as the sudden and unexpected attack on an unsuspecting victim, depriving the victim of any chance to defend themselves. In this case, the victim’s blindness and old age were critical factors in determining the presence of treachery.
Why was the victim’s dying declaration not considered?	The victim’s dying declaration was not considered because the defense successfully argued that her blindness made it impossible for her to identify her attacker. The prosecution failed to establish a sufficient level of familiarity between the victim and the accused, casting doubt on her ability to make a reliable identification.
How did the Court assess the credibility of the eyewitness?	The Court assessed the credibility of the eyewitness, Apolinario Caigoy, by considering his vantage point and the consistency of his testimony. Minor inconsistencies were deemed not to discredit his account, and there was no evidence of ill motive that would lead him to falsely testify against the accused.
What is the significance of “positive identification” in this case?	The positive identification of the accused by the eyewitness was a critical factor in the Court’s decision. It outweighed the accused’s denial, which was considered a weak defense, especially in the absence of clear and convincing evidence to support it.
What penalty was imposed on the accused?	The accused was sentenced to reclusion perpetua without eligibility for parole. While the aggravating circumstance of disregard for the victim’s age and sex could have warranted the death penalty, it was not imposed due to Republic Act No. 9346, which prohibits the death penalty.
What damages were awarded to the victim’s heirs?	The victim’s heirs were awarded P100,000.00 as civil indemnity, P100,000.00 as moral damages, and P100,000.00 as exemplary damages. These damages were awarded to compensate for the loss and suffering caused by the crime, and to serve as a deterrent against similar acts.
How does this case affect future murder cases in the Philippines?	This case reinforces the importance of credible eyewitness testimony and the presence of treachery in determining guilt in murder cases. It also highlights the Court’s commitment to protecting vulnerable members of society and ensuring that perpetrators are held accountable.

This ruling in People v. Colorada serves as a crucial reference point for future cases involving murder, treachery, and the evaluation of eyewitness testimony. It underscores the necessity of a thorough and impartial examination of evidence to ensure that justice is served, and the rights of victims are protected.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: People of the Philippines vs. Edcel Colorada, G.R. No. 215715, August 31, 2016