In the case of People of the Philippines vs. Antonio Edaño, the Supreme Court affirmed the conviction of Antonio Edaño for murder, emphasizing that the testimony of a credible eyewitness is sufficient for conviction, even if the witness did not see the entire sequence of events. The Court also reiterated that treachery qualifies a killing as murder when the method employed ensures the safety of the assailant by rendering the victim defenseless, reinforcing the principle that a coordinated attack eliminating any chance of self-defense constitutes treachery under the law.

Moonlit Witness: Can Darkness Obscure Justice in a Murder Case?

The case revolves around the fatal stabbing of Leonardo Dabalos on March 21, 1999, in Leyte, Philippines. Antonio Edaño, along with Nestor Edaño, was accused of conspiring to kill Dabalos. The prosecution’s key witness, Fernando Layson, testified that he saw Antonio stabbing Leonardo while Nestor held the victim’s arms. Though Nestor was previously convicted, Antonio remained at large until his arrest in 2005. At trial, Antonio Edaño contested the credibility of Fernando’s testimony, citing improbabilities and a supposed motive for false accusation, setting the stage for a legal challenge centered on the reliability of eyewitness accounts and the characterization of the crime.

At the heart of the court’s decision was the admissibility and weight of the eyewitness testimony. The Supreme Court affirmed the utilization of Fernando’s testimony, presented in the earlier trial of Nestor Edaño, emphasizing the exception to the hearsay rule under Section 47, Rule 130 of the Rules of Court. This rule allows for the admission of testimony from a deceased witness given in a former proceeding, provided the current party had an opportunity to cross-examine the witness in the previous case. Because Fernando Layson had testified against Nestor, and Antonio Edaño had the opportunity to challenge that testimony, it was deemed admissible in the case against Antonio.

Building on this principle, the Court addressed the defense’s argument that Fernando’s testimony was unreliable due to the darkness of the evening. The Court referenced People v. Lopez, stating that moonlight provides sufficient illumination for witness identification. Fernando himself confirmed it was a moonlit night, clarifying that visibility was adequate. This reaffirmed a long-standing precedent that acknowledges environmental context in evaluating eyewitness accounts. The Court also addressed the argument concerning Fernando’s failure to intervene during the stabbing.

Thus, witness [Fernando] cannot be faulted for reacting the way he did during the incident. Human experience dictates that when a person is confronted with a threatening environment, the natural reaction is to secure his safety. Indeed, this is what [Fernando] did in staying home with his brother for the night. It is to be noted that upon the break of first light the following day, Fernando reported what he witnessed to the authorities as early as 5:00 a.m. He went on to break the news to the victim’s family an hour after. These actions are conformable with his sworn statement and are logical responses considering his recent traumatic experience.

Regarding the discrepancy between the three stabs Fernando claimed to witness and the seven wounds found on Leonardo, the court offered a rational explanation. The court inferred that the attack was ongoing, and more injuries could have been inflicted before and after Fernando’s brief observation. The court also dismissed the accused-appellant’s claims that Fernando held a grudge. Antonio could not provide substantial evidence supporting his allegations of ill motive. Furthermore, Antonio’s flight to elude arrest for six years was viewed as inconsistent with a claim of innocence.

The Supreme Court underscored the presence of treachery, which elevated the crime to murder. Treachery exists when the offender employs means, methods, or forms in the execution of the crime that directly and especially ensure its execution without risk to the offender arising from the defense which the offended party might make. The requisites of treachery, as defined in Cirera v. People, are:

(1) The employment of means, method, or manner of execution which will ensure the safety of the malefactor from defensive or retaliating acts on the part of the victim, no opportunity being given to the latter to defend himself or to retaliate; and

(2) Deliberate or conscious adoption of such means, method, or manner of execution.

In Edaño’s case, treachery was evident because Leonardo’s arms were restrained by Nestor while Antonio stabbed him. This coordinated method deprived Leonardo of any opportunity to defend himself, thereby satisfying the elements of treachery. The Court cited Article 248 of the Revised Penal Code, which prescribes the penalty for murder as reclusion perpetua to death. Given the absence of any aggravating circumstances, the accused-appellant was sentenced to reclusion perpetua. However, the Court clarified that the accused-appellant is not eligible for parole, aligning with Section 3 of Republic Act No. 9346.

In line with prevailing jurisprudence, the Supreme Court augmented the damages awarded. The civil indemnity was increased to P75,000.00, and exemplary damages to P30,000.00. Moral damages of P75,000.00 were deemed proper, recognizing the emotional distress suffered by the victim’s family. Since the lower courts did not award actual damages, the Supreme Court awarded temperate damages of P25,000.00, acknowledging the pecuniary loss sustained by the victim’s heirs. All damages were set to accrue interest at 6% per annum from the finality of the judgment until fully paid.

In sum, this ruling serves as a powerful reminder of the probative value of credible eyewitness testimony and highlights how acts of treachery can elevate a crime to murder. The Supreme Court’s meticulous analysis of the facts, adherence to legal principles, and careful consideration of damages demonstrate the justice system’s commitment to addressing heinous crimes and providing reparations to victims’ families.

FAQs

What was the key issue in this case?	The key issue was whether the testimony of a single eyewitness, Fernando Layson, was sufficient to convict Antonio Edaño of murder, considering the challenges to his credibility and the circumstances under which he witnessed the crime. The case also examined whether the killing was qualified by treachery.
Why was Fernando Layson’s testimony considered credible?	Despite defense arguments about darkness and limited observation, the court found his testimony credible because he knew the accused, the night was moonlit, and his account was consistent with his earlier sworn statement. The court also considered his fear as a reasonable explanation for not intervening.
What is treachery, and how did it apply in this case?	Treachery is the employment of means to ensure the execution of a crime without risk to the offender from the victim’s defense. Here, it applied because Nestor Edaño held Leonardo Dabalos’ arms, preventing him from defending himself against Antonio Edaño’s stabs.
What damages were awarded to the victim’s heirs?	The court ordered Antonio Edaño to pay P75,000.00 as civil indemnity, P75,000.00 as moral damages, P30,000.00 as exemplary damages, and P25,000.00 as temperate damages, plus interest at 6% per annum from the finality of the judgment until fully paid.
What is the significance of the case in terms of criminal law?	The case reinforces the principle that eyewitness testimony, if deemed credible, can be sufficient for a murder conviction, even if the witness did not observe the entire sequence of events. It also clarifies the elements of treachery, emphasizing that a coordinated attack eliminating any chance of self-defense constitutes treachery under the law.
Can someone convicted of murder and sentenced to reclusion perpetua be eligible for parole?	No, according to Section 3 of Republic Act No. 9346, individuals convicted of offenses punishable by reclusion perpetua are not eligible for parole.
What is the hearsay rule, and how does it relate to this case?	The hearsay rule generally prohibits the admission of out-of-court statements offered to prove the truth of the matter asserted. However, an exception exists when a deceased witness’s testimony from a previous trial involving the same parties and subject matter can be admitted, as long as the opposing party had an opportunity to cross-examine the witness in the prior proceeding, as was the case with Fernando Layson’s testimony.
How did the court address the discrepancy between the number of wounds and the witness’s testimony?	The court inferred that the stabbing was an ongoing event, and the witness may not have seen the entire attack. Additional wounds could have been inflicted before or after the period he observed, thus reconciling the discrepancy.

The affirmation of Antonio Edaño’s conviction underscores the critical role of eyewitness testimony and the legal definition of treachery in Philippine law. This case continues to inform jurisprudence regarding the standards of evidence required for a murder conviction.

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. ANTONIO EDAÑO, G.R. No. 206970, July 29, 2015