In the case of People of the Philippines vs. Charlie Nazareno, the Supreme Court affirmed the conviction of the accused for murder, emphasizing the significance of eyewitness testimony and the presence of treachery in the commission of the crime. The Court held that minor inconsistencies in witness statements do not undermine their credibility when the core testimony is consistent and corroborated by forensic evidence. This decision underscores the principle that a sudden and unexpected attack on a defenseless victim, particularly one roused from sleep, constitutes treachery, thereby elevating the crime to murder. This ruling reinforces the importance of credible eyewitness accounts and the rigorous application of the principle of treachery in Philippine criminal law.

From Slumber to Slaughter: How Treachery Defined a Murder Conviction

The narrative of the case unfolds with Charlie Nazareno being charged with the murder of Romeo de Guzman. The prosecution presented Jericho Capanas, an eyewitness, who testified that he saw Nazareno attacking de Guzman with a bolo after kicking open his door. The victim, who had been sleeping, was stabbed in the chest and hacked on the ear. The defense presented a conflicting account, claiming that Nazareno and de Guzman had been drinking together and that a fight ensued when de Guzman asked Nazareno to take revenge on an enemy. The trial court found Nazareno guilty of murder, a decision affirmed by the Court of Appeals. The central issue before the Supreme Court was whether the prosecution had proven Nazareno’s guilt beyond a reasonable doubt and whether treachery attended the commission of the crime.

The Supreme Court scrutinized the alleged inconsistencies in Jericho Capanas’s testimony, which the defense claimed undermined his credibility. However, the Court found that these inconsistencies were minor and did not detract from the substance of his account. Credibility of witnesses is a crucial aspect in any trial, and the court emphasized that absent any indication of improper motive, a witness’s positive and categorical declarations deserve full faith and credence. The Court stated:

Absent any showing that a witness for the prosecution was actuated by improper motive, his positive and categorical declarations on the witness stand, under the solemnity of an oath, deserve full faith and credence.

Further solidifying the prosecution’s case, the medico-legal officer’s testimony corroborated Capanas’s account, confirming that the victim sustained stab wounds to the chest and ear. Moreover, Nazareno himself, in a letter to the victim’s brother, asked for forgiveness, an act the Court deemed analogous to an attempt to compromise, which can be received as an implied admission of guilt under Section 27, Rule 130 of the Rules of Court. In this context, implied admission of guilt serves as a potent piece of evidence against the accused. Section 27 of Rule 130 states:

In criminal cases, except those involving quasi-offense (criminal negligence) or those allowed by law to be compromised, an offer of compromise by the accused may be received in evidence as an implied admission of guilt.

In addition to the letter, Nazareno admitted on the witness stand to having killed de Guzman. This admission was deemed a judicial admission of guilt, which, under Section 26 Rule 130 of the Rules of Court, can be used as evidence against him. The Court highlighted that these admissions, coupled with the eyewitness testimony, provided overwhelming evidence of Nazareno’s guilt.

The Court then turned to the critical question of whether treachery attended the commission of the crime. Treachery, as a qualifying circumstance, elevates the crime to murder, as defined in Article 248 of the Revised Penal Code. The Supreme Court has consistently held that an attack on a victim who has just awakened or been roused from sleep constitutes treachery. In such a state, the victim is unable to mount any form of defense. The Court underscored this point, stating:

Time and again, the Supreme Court has held that an attack on a victim who has just wakened or who was roused from sleep is one attended by treachery because in such situation, the victim is in no position to put up any form of defense.

The essence of treachery lies in the swift and unexpected attack on an unsuspecting and unarmed victim, ensuring the accomplishment of the assailant’s purpose without risk to himself. The facts of the case clearly indicated that de Guzman was not aware of the impending attack. He had just awakened when Nazareno stabbed him, having been roused from sleep by Nazareno’s act of kicking the door behind which the victim usually slept. Additionally, the victim was intoxicated, further diminishing his ability to defend himself. These circumstances unequivocally established the presence of treachery, which qualified the crime as murder.

Regarding the damages awarded, the Court addressed each type separately. Civil indemnity is mandatory in murder cases and is granted to the heirs of the victim without the need for proof beyond the commission of the crime. The Court increased the amount of civil indemnity to P75,000.00 to conform with recent jurisprudence. Moral damages were also correctly awarded, as they require no further proof than the fact of death and the resulting grief to the victim’s family. The Court upheld the award of P50,000.00 for moral damages.

Exemplary damages are imposed when aggravating circumstances attend the commission of the crime. Given the presence of treachery, the Court deemed the award of exemplary damages warranted and increased the amount to P30,000.00. Finally, temperate damages are awarded when pecuniary loss is suffered but cannot be proven with certainty. While the victim’s brother testified to funeral and hospital expenses, he failed to present receipts. Therefore, the Court found the award of temperate damages in the amount of P25,000.00 to be proper.

FAQs

What was the key issue in this case?	The key issue was whether Charlie Nazareno’s guilt for the murder of Romeo de Guzman was proven beyond a reasonable doubt, and whether the crime was committed with treachery.
What is the significance of eyewitness testimony in this case?	The eyewitness testimony of Jericho Capanas was crucial as it provided a direct account of the stabbing, which was corroborated by forensic evidence and the accused’s own admissions.
How did the Court define treachery in this context?	The Court defined treachery as a sudden and unexpected attack on an unsuspecting and defenseless victim, particularly one who is roused from sleep and thus unable to defend themselves.
What was the impact of the accused’s letter seeking forgiveness?	The letter seeking forgiveness was considered analogous to an attempt to compromise, which the Court interpreted as an implied admission of guilt, further strengthening the prosecution’s case.
What is a judicial admission of guilt, and how did it apply to this case?	A judicial admission of guilt is a statement made by the accused during the trial that admits their involvement in the crime, which can be used as evidence against them; Nazareno admitted to killing de Guzman on the witness stand.
Why were civil indemnity and moral damages awarded?	Civil indemnity is mandatory in murder cases, while moral damages are awarded to compensate the victim’s family for the grief and suffering caused by the violent death; both require no further proof beyond the commission of the crime.
What are exemplary damages, and why were they imposed in this case?	Exemplary damages are imposed as part of the civil liability arising from the crime when aggravating circumstances, such as treachery, are present in the commission of the offense.
Why were temperate damages awarded instead of actual damages?	Temperate damages were awarded because the heirs suffered pecuniary loss, but they could not provide documentary evidence such as receipts to prove the exact amount of the expenses incurred.

The Supreme Court’s decision in People vs. Nazareno underscores the critical role of eyewitness testimony, the legal implications of an admission of guilt, and the significance of treachery as a qualifying circumstance in murder cases. This ruling not only provides clarity on the application of these legal principles but also serves as a reminder of the importance of ensuring justice for victims of violent crimes. The meticulous evaluation of evidence and the affirmation of established legal doctrines reinforce the integrity of the Philippine justice system in addressing heinous crimes.

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. Charlie Nazareno y Melanios, G.R. No. 180915, August 09, 2010