People v. Enriquez

 

People v. Enriquez

G.R. No. 238171

June 19, 2019

FACTS:

                The RTC and CA convicted Arnaldo Enriquez, Jr. for the crime of Murder under Art. 248 of the RPC. On December 30, 2006, at around 9:30 in the evening, Luisa and her daughter, Jessica, were in their house watching the television when they heard someone moaning at a nearby house. As they peeped out of the window, they saw a bloodied Dela Cruz coming out of his house and upon reaching the door got stabbed in the back by Enriquez with a bread knife. Dela Cruz managed to ask for help from his uncle's house before collapsing. He was then brought to the hospital but was unfortunately pronounced dead on arrival caused by multiple stab wounds in the neck and thorax. On the same date, at around 10:30 in the evening, Barangay Security Development Officer Obar received a call about a killing incident in Carreon Village. He went to the reported place and upon arrival, he saw a person being mauled and learned from an unnamed woman [that said person is] the one involved in the killing. He arrested this person whom he later identified as Enriquez. After bringing him to the barangay, Obar returned to the place and recovered a knife. Meanwhile, Enriquez was transferred to Camp Karingal.

ISSUE:

                Whether or not the CA erred in affirming Enriquez’s conviction for Murder

HELD:

                Yes. It is established that the qualifying circumstance of treachery must be proven by clear and convincing evidence. Thus, for Enriquez to be convicted of Murder, the prosecution must not only establish that he killed Dela Cruz; it must also be proven that the killing of Dela Cruz was attended by treachery. In a catena of cases, the Court has consistently held that treachery cannot be appreciated where the prosecution only proved the events after theattack happened, but not the manner of how the attack commenced or how the act which resulted in the victim's death unfolded. In treachery, there must be clear and convincing evidence on how the aggression was made, how it began, and how it developed. Where no particulars are known as to the manner in which the aggression was made or how the act which resulted in the death of the victim began and developed, it cannot be established from suppositions drawn only from circumstances prior to the very moment of the aggression, that an accused perpetrated the killing with treachery. Accordingly, treachery cannot be considered where the lone witness did not see the commencement of the assault. In the instant case, the evidence presented by the prosecution only proved the events after the initial attack had already happened. The prosecution witnesses, Luisa and Jessica, did not see the manner of how the attack commenced or how the acts which resulted in the victim's death unfolded as the attack started inside the house of the victim. They merely saw Dela Cruz, already bloodied, coming out of his house. It was only at this point that they saw Enriquez stab the victim again with a bread knife. Thus, what happened inside the house is unknown to the prosecution witnesses. Moreover, the finding of the trial court, sustained by the CA, that treachery was present proceeds only from the fact that the witnesses saw Enriquez stab the already bloodied victim from behind as he was about to exit his house. Wherefore, Enriquez, guilty of Homicide.

 

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