In People v. Labitad, the Supreme Court modified the lower court’s decision, reclassifying the crime from murder to homicide due to the prosecution’s failure to conclusively prove the presence of treachery and evident premeditation. The accused, initially convicted of murder, had his sentence reduced, highlighting the critical importance of establishing each element of a crime beyond a reasonable doubt. This ruling emphasizes that the lack of sufficient evidence regarding qualifying circumstances can significantly alter the outcome of a criminal case.

A Brother’s Betrayal: When Relationship Doesn’t Prove Guilt in the Panga Hill Stabbing

The case began with the brutal stabbing of Apolonio Vertudazo in Cebu City on July 13, 1997. Dionisio Labitad, the victim’s brother-in-law, was accused of the crime. The prosecution presented Avelino Nadera, an eyewitness, who testified he saw Labitad stabbing Vertudazo with a “plamingko.” Nadera’s testimony was crucial, as he identified Labitad as the perpetrator. However, Nadera also admitted to delaying his disclosure due to fear, as Labitad had threatened him after the incident. The defense countered with a denial and alibi, claiming Labitad was at home gathering firewood at the time of the murder, supported by his wife and a neighbor. The Regional Trial Court initially convicted Labitad of murder, but the Supreme Court reviewed the case focusing on whether treachery and evident premeditation were sufficiently proven.

The Supreme Court carefully examined the evidence presented, particularly the testimony of the eyewitness. While the court acknowledged the witness’s initial hesitation in reporting the crime due to fear, it ultimately found his testimony credible. Credibility of witnesses, the Court emphasized, is best assessed by the trial court, which has the opportunity to observe their demeanor and manner of testifying. As the Court stated, appellate courts generally defer to the trial courts’ findings on credibility:

The Court has consistently held that when it comes to the issue of credibility of witnesses, appellate courts generally will not overturn the findings of the trial courts. They are in the best position to ascertain and measure the sincerity and spontaneity of witnesses through their actual observation of the witnesses’ manner of testifying, demeanor and behavior in court.

Despite upholding the eyewitness’s credibility, the Supreme Court scrutinized the presence of qualifying circumstances necessary to elevate the crime to murder. The information filed against the accused stated:

That on or about the 13th day of July 1997, at about 3:30 P.M., in the City of Cebu, Philippines, and within the jurisdiction of this Honorable Court, the said accused, armed with a deadly weapon locally known as plamingko, with intent to kill and with treachery and evident premeditation, did then and there attack, assault and stab one Apolonio Vertudazo with the plamingko hitting the latter on the different parts of his body and inflicting upon him the following physical injuries, causing:

“SECONDARY TO MULTIPLE STAB WOUNDS, THORACO ABDOMINAL AREA, ANTERIOR AND POSTERIOR ASPECTS.”

Treachery, under Philippine law, requires that the offender employ means, methods, or forms in the execution of the crime that tend directly and specially to ensure its execution, without risk to himself arising from the defense which the offended party might make. Evident premeditation, on the other hand, necessitates proof of the time when the offender determined to commit the crime, an act manifestly indicating that the culprit had clung to his determination, and a sufficient lapse of time between the determination and the execution to allow him to reflect upon the consequences of his act.

The Court found that the prosecution failed to provide sufficient evidence to prove either treachery or evident premeditation beyond a reasonable doubt. The eyewitness’s testimony merely described the act of stabbing itself, without detailing how the attack was executed to ensure its success without risk to the accused. Similarly, there was no evidence presented regarding the planning or reflection period necessary to establish evident premeditation. The Supreme Court has consistently held that:

For these qualifying circumstances to be considered, they must be established as conclusively as the crime itself.

Since the qualifying circumstances were not adequately proven, the Court reclassified the crime to homicide, defined and penalized under Article 249 of the Revised Penal Code. This article stipulates that:

Any person who, not falling within the provisions of Article 246, shall kill another without the attendance of any of the circumstances enumerated in Article 248, shall be deemed guilty of culpable homicide and shall be punished by reclusion temporal.

The penalty for homicide is reclusion temporal, which ranges from twelve years and one day to twenty years. Given the absence of any mitigating or aggravating circumstances, the Court applied the Indeterminate Sentence Law, sentencing Labitad to an indeterminate penalty of eight years of prision mayor as minimum, to sixteen years of reclusion temporal as maximum. This law allows for a sentence with a minimum and maximum term, affording the convict an opportunity for parole.

In addition to the prison sentence, the Court addressed the civil liabilities of the accused. It upheld the award of P50,000.00 as civil indemnity for the death of the victim. Furthermore, it awarded P50,000.00 as moral damages, recognizing the emotional suffering endured by the victim’s family. In determining the economic loss suffered by the heirs, the Court applied the formula for computing loss of earning capacity, as the following:

Net	=	Life expectancy	x	Gross Annual Income (GAI)	–	Living expenses
Earning		[2/3 (80-age at death)]
Capacity

Based on the victim’s income as a baker and his age at the time of death, the Court computed the loss of earning capacity to be P626,640.00. This amount was awarded to the heirs as indemnity for the economic loss they sustained due to the victim’s untimely death.

FAQs

What was the key issue in this case?	The key issue was whether the prosecution presented sufficient evidence to prove the qualifying circumstances of treachery and evident premeditation, which would justify a conviction for murder rather than homicide. The Supreme Court ultimately ruled that the evidence was insufficient to prove these circumstances beyond a reasonable doubt.
What is the difference between murder and homicide?	The main difference lies in the presence of qualifying circumstances. Murder requires the presence of specific elements such as treachery, evident premeditation, or cruelty, while homicide is the unlawful killing of another person without these qualifying circumstances.
What is treachery?	Treachery is the employment of means, methods, or forms in the execution of a crime that tend directly and especially to ensure its execution, without risk to the offender arising from the defense which the offended party might make. It essentially means the attack was sudden and unexpected, giving the victim no chance to defend themselves.
What is evident premeditation?	Evident premeditation requires proof of the time when the offender determined to commit the crime, an act manifestly indicating that the culprit clung to their determination, and a sufficient lapse of time between the determination and the execution to allow them to reflect upon the consequences of their act. It shows that the killing was planned and thought out beforehand.
Why was the accused’s alibi not accepted by the court?	The accused’s alibi was not accepted because he failed to prove that it was physically impossible for him to be present at the scene of the crime. The Court found that the distance between his house and the crime scene was relatively short and could be traversed in a reasonable amount of time.
What is the Indeterminate Sentence Law?	The Indeterminate Sentence Law allows the court to impose a sentence with a minimum and maximum term, rather than a fixed sentence. This gives the convict the possibility of parole after serving the minimum term, based on their behavior and rehabilitation.
What civil liabilities were imposed on the accused?	The accused was ordered to pay the heirs of the victim P50,000.00 as civil indemnity, P50,000.00 as moral damages, and P626,640.00 as indemnity for the victim’s loss of earning capacity. These damages are intended to compensate the victim’s family for the loss and suffering they have endured.
How is the loss of earning capacity calculated?	The loss of earning capacity is calculated using a formula that takes into account the victim’s life expectancy, gross annual income, and living expenses. The formula is: Net Earning Capacity = Life expectancy [2/3 (80-age at death)] x Gross Annual Income (GAI) – Living expenses (50% of GAI).

The Labitad case serves as a reminder of the stringent requirements for proving qualifying circumstances in criminal cases. While the eyewitness testimony established the accused’s involvement in the killing, the absence of concrete evidence demonstrating treachery and evident premeditation led to the reclassification of the crime. This decision underscores the importance of thorough investigation and presentation of evidence to ensure that justice is served accurately and fairly.

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 v. Labitad, G.R. No. 132793, May 07, 2002