In People v. Nasayao, the Supreme Court affirmed the conviction of Jose Nasayao y Borromeo, Sr. for murder, emphasizing the importance of establishing treachery in determining criminal liability. The court highlighted that treachery exists when an offender employs means to ensure the execution of a crime against a person without risk to themselves, arising from the defense which the offended party might make. This ruling clarifies how sudden and unexpected attacks qualify as treachery, thereby elevating the crime from homicide to murder, ensuring justice for victims and reinforcing the gravity of such offenses under Philippine law.

Unexpected Assault: How Treachery Defined Murder in Nasayao’s Case

This case revolves around the tragic death of Joves Camata, who was stabbed to death by Jose Nasayao y Borromeo, Sr. on April 20, 1999. The incident occurred while Camata was watching television at a friend’s house. Nasayao approached Camata and, without warning, stabbed him multiple times, resulting in his death. The central legal question was whether the killing was attended by treachery, which would qualify the crime as murder, or whether it was simply homicide, as argued by the accused-appellant.

The prosecution presented eyewitness accounts from Marnel Casabuena and Anthony Buelva, who testified that Nasayao approached Camata without any warning and stabbed him. Dr. Dante B. Bausa, the Municipal Health Officer, confirmed that Camata sustained two fatal stab wounds. Nasayao admitted to the stabbing but claimed it was accidental and occurred after Camata attacked him first. The trial court found Nasayao guilty of murder, leading to this appeal where the defense argued that the prosecution witnesses were not credible and that the killing, at most, constituted homicide.

A key point of contention was the credibility of the prosecution witnesses. Nasayao argued that there were inconsistencies in their testimonies, such as the television program they were watching and the number of stab wounds inflicted. However, the Supreme Court dismissed these inconsistencies as minor details that did not affect the overall credibility of the witnesses. The court reiterated the principle that findings of the trial court regarding the credibility of witnesses are given great weight, unless there is a failure to appreciate certain facts. The court stated,

This Court has consistently ruled that findings of the trial court as to the credibility of witnesses are accorded great weight, even finality, on appeal, unless the trial court has failed to appreciate certain facts and circumstances, which, if taken into account, would materially affect the result of the case.

The Supreme Court emphasized that slight contradictions in testimonies do not necessarily impair the weight of the united testimony to the prominent facts. Instead, such contradictions can strengthen the sincerity of a witness and prove that the testimony is not rehearsed. The court also noted that different persons may have different impressions or recollections of the same incident, leading to minor inconsistencies. These differences are considered normal and do not discredit the witnesses’ overall testimony.

The prosecution successfully argued that the killing was attended by treachery. The Supreme Court agreed, noting that Camata was in a vulnerable position when he was attacked. He was squatting on a bench, eating, and holding a plate, making it difficult for him to defend himself. The court noted,

The victim, while squatting on top of a bench and eating his meal with a plate in one hand, was certainly in no position to defend himself or to retaliate.

The sudden and unexpected nature of the attack further supported the finding of treachery. Even though Nasayao told Camata to finish his meal, he did not give him a chance to stand up or react. This element of surprise ensured that Camata could not defend himself, thereby fulfilling the requirements for treachery under Philippine law.

The legal framework for treachery is well-established in Philippine jurisprudence. Treachery is defined as the employment of means, methods, or forms in the execution of a crime against persons that tend directly and specially to ensure its execution, without risk to the offender arising from the defense which the offended party might make. The key elements are the suddenness of the attack and the defenselessness of the victim. The Supreme Court, citing previous decisions, reiterated that treachery may still be appreciated even when the victim was forewarned of the danger, as long as the execution of the attack made it impossible for the victim to defend himself. The court emphasized,

There is treachery when the offender commits any of the crimes against persons, employing means, methods, or forms in the execution thereof which tend directly and specially to insure its execution, without risk to himself arising from the defense which the offended party might make.

In cases involving claims of self-defense, the burden of proof lies with the accused to prove the elements of self-defense. These elements include unlawful aggression on the part of the victim, reasonable necessity of the means employed to prevent or repel the unlawful aggression, and lack of sufficient provocation on the part of the person defending himself. In this case, Nasayao claimed that Camata attacked him first, but the court found this claim unconvincing. The prosecution’s evidence and the nature of the stab wounds suggested that Nasayao was the aggressor.

The Supreme Court affirmed the trial court’s decision finding Nasayao guilty of murder. However, the Court modified the award of civil indemnity to the heirs of Joves Camata, reducing it from P75,000.00 to P50,000.00, in line with prevailing jurisprudence. Additionally, the Court awarded exemplary damages in the amount of P25,000.00, considering the presence of the qualifying circumstance of treachery. The court clarified that exemplary damages are recoverable if there is an aggravating circumstance in the commission of the crime. This adjustment reflects the court’s commitment to aligning the awards with established legal principles.

The court’s decision reinforces the significance of treachery as a qualifying circumstance that elevates homicide to murder. This ruling underscores the importance of protecting individuals from sudden and unexpected attacks, ensuring that offenders are held accountable for their actions. By clarifying the application of treachery, the Supreme Court provides guidance to lower courts and reinforces the principles of justice in Philippine criminal law.

FAQs

What was the key issue in this case?	The key issue was whether the killing of Joves Camata by Jose Nasayao y Borromeo, Sr. was attended by treachery, which would qualify the crime as murder.
What is treachery in Philippine law?	Treachery is the employment of means, methods, or forms in the execution of a crime against persons that tend directly and specially to ensure its execution, without risk to the offender arising from the defense which the offended party might make.
How did the Supreme Court define treachery in this case?	The Supreme Court reiterated that treachery occurs when the offender commits a crime against a person using means that ensure its execution without any risk to themselves.
What evidence did the prosecution present?	The prosecution presented eyewitness accounts and the autopsy report to show that Nasayao suddenly attacked Camata while he was defenseless.
What was the accused-appellant’s defense?	Nasayao admitted to the stabbing but claimed it was accidental and occurred after Camata attacked him first.
Why were the inconsistencies in the witnesses’ testimonies dismissed?	The Supreme Court considered the inconsistencies as minor details that did not affect the overall credibility of the witnesses.
What was the final ruling of the Supreme Court?	The Supreme Court affirmed the trial court’s decision finding Nasayao guilty of murder, but modified the civil indemnity and awarded exemplary damages.
What damages were awarded to the heirs of the victim?	The heirs of Joves Camata were awarded P50,000.00 as civil indemnity and P25,000.00 as exemplary damages.

The People v. Nasayao case serves as a crucial reminder of the application of treachery in determining criminal liability. The decision underscores the importance of protecting individuals from sudden and unexpected attacks, ensuring that offenders are held accountable for their actions, and clarifies the circumstances under which an act can be classified as murder rather than homicide.

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. Jose Nasayao y Borromeo, Sr., G.R. No. 141237, September 17, 2002