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GR No. 197813

2013-09-25

PEREZ, J.

Finally, we affirm the lower court's award of damages consistent with jurisprudence:[15] (1) P50,000.00 as civil indemnity; (2) P25,000.00 as temperate damages; and (3) P50,000.00 as moral damages. Consistent with current jurisprudence, we increase the award of exemplary damages from P25,000.00 to P30,000.00.[16] However, we delete the award of P1,946,180.00 representing the unearned income of Wilfredo.

GR No. 198110

2013-07-31

PEOPLE v. WILSON ROMAN

REYES, J.

The award of civil indemnity is mandatory and granted to the heirs of the victim without need of proof other than the commission of the crime. It requires only the establishment of the fact of death as a result of the crime and that the accused-appellant is responsible thereto.[56] However, in order to conform with the prevailing jurisprudence, the civil indemnity awarded to the heirs of victim must be raised to P75,000.00.[57]

GR No. 182523

2012-09-15

PEOPLE v. EFREN LAURIO Y ROSALES

LEONARDO-DE CASTRO, J.

The Court has often stated that factual findings of the trial court as regards its assessment of the witnesses' credibility are entitled to great weight and respect particularly when the Court of Appeals affirms the said findings, and will not be disturbed absent any showing that the trial court overlooked certain facts and circumstances which could substantially affect the outcome of the case.[20] It is the trial judge who had the opportunity to observe the witnesses' demeanor and deportment on the stand, and the manner in which they gave their testimonies.[21] The trial judge therefore is in a better position to determine the veracity of the witnesses' testimony.[22]

GR No. 184500

2012-09-11

PEOPLE OF PIIILIPPINES v. WENCESLAO NELMIDA

PEREZ, J.

As to penalty. Under Article 248 of the Revised Penal Code, the penalty imposed for the crime of murder is reclusion perpetua to death. There being neither aggravating nor mitigating circumstance, the penalty to be imposed upon appellants is reclusion perpetua for each count, pursuant to paragraph 2, Article 63[104] of the Revised Penal Code.[105]

GR No. 175781

2012-03-20

PEOPLE v. FRANCISCA TALARO

PERALTA, J.

Lolito Aquino's admission, and accused-appellants' positive identification of Raymundo Zamora and Rodolfo Duzon cannot be belied by accused-appellants' mere denial. It is established jurisprudence that denial and alibi cannot prevail over the witness' positive identification of the accused-appellants.[24] Moreover, accused-appellants could not give any plausible reason why Raymundo Zamora would testify falsely against them. In People v. Molina,[25] the Court expounded, thus: In light of the positive identification of appellant by the prosecution witnesses and since no ill motive on their part or on that of their families was shown that could have made either of them institute the case against the appellant and falsely implicate him in a serious crime he did not commit, appellant's defense of alibi must necessarily fail. It is settled in this jurisdiction that the defense of alibi, being inherently weak, cannot prevail over the clear and positive identification of the accused as the perpetrator of the crime. x x x[26] (Emphasis supplied)

GR No. 192465

2011-06-08

PEOPLE v. ANGELITO ESQUIBEL Y JESUS

CARPIO, J.

Further, we agree with the lower courts in appreciating treachery as a qualifying circumstance. The essence of treachery is the sudden and unexpected attack on an unsuspecting victim by the perpetrator of the crime, depriving the victim of any chance to defend himself or repel the aggression, thus, insuring its commission without risk to the aggressor and without any provocation on the part of the victim.[14] The sudden attack by Esquibel with a bladed weapon, with Baloloy's back against him, was undoubtedly treacherous. Baloloy was washing his hands outside his house when Esquibel appeared out of nowhere and stabbed him. Baloloy was unprepared and had no means to put up a defense. Such aggression insured the commission of the crime without risk on Esquibel.

GR No. 178771

2011-06-08

PEOPLE v. ALBERTO ANTICAMARA Y CABILLO

PERALTA, J.

In Criminal Case No. 4498-R, the award of civil indemnity is mandatory and granted to the heirs of the victim without need of proof other than the commission of the crime. [61] In People v. Quiachon, [62] even if the penalty of death is not to be imposed because of the prohibition in R.A. 9346, the civil indemnity of P75,000.00 is proper, because it is not dependent on the actual imposition of the death penalty but on the fact that qualifying circumstances warranting the imposition of the death penalty attended the commission of the offense. As explained in People v. Salome, [63] while R.A. No. 9346 prohibits the imposition of the death penalty, the fact remains that the penalty provided for by law for a heinous offense is still death, and the offense is still heinous. Accordingly, the award of civil indemnity in the amount of P75,000.00 is proper.

GR No. 178272

2011-03-14

PEOPLE v. RODRIGO SALCEDO

PERALTA, J.

The award of civil indemnity is mandatory and granted to the heirs of the victim without need of proof other than the commission of the crime.[51] The Court affirms the award of civil indemnity given by the trial court and the CA in the amount of PhP50,000.00.

GR No. 189580

2011-02-09

PEOPLE v. ALVIN DEL ROSARIO

NACHURA, J.

The age-old rule is that the task of assigning values to the testimonies of witnesses and weighing their credibility is best left to the trial court which forms first-hand impressions as witnesses testify before it. It is thus no surprise that findings and conclusions of trial courts on the credibility of witnesses enjoy, as a rule, a badge of respect, for trial courts have the advantage of observing the demeanor of witnesses as they testify.[16] Further, factual findings of the trial court as regards its assessment of the witnesses' credibility are entitled to great weight and respect by this Court, particularly when the CA affirms the said findings, and will not be disturbed absent any showing that the trial court overlooked certain facts and circumstances which could substantially affect the outcome of the case.[17]

GR No. 186420

2009-08-25

PEOPLE v. SAMUEL ANOD

NACHURA, J.

As to damages, we held in People of the Philippines v. Judito Molina and John Doe, and Joselito Tagudar,[14] that when death occurs due to a crime, the following damages may be awarded: (1) civil indemnity ex delicto for the death of the victim; (2) actual or compensatory damages; (3) moral damages; (4) exemplary damages; and (5) temperate damages.

	GR No. 197813 2013-09-25	PEOPLE v. EDWIN IBAÑEZ Y ALBANTE PEREZ, J.
Finally, we affirm the lower court's award of damages consistent with jurisprudence:[15] (1) P50,000.00 as civil indemnity; (2) P25,000.00 as temperate damages; and (3) P50,000.00 as moral damages. Consistent with current jurisprudence, we increase the award of exemplary damages from P25,000.00 to P30,000.00.[16] However, we delete the award of P1,946,180.00 representing the unearned income of Wilfredo.
	GR No. 198110 2013-07-31	PEOPLE v. WILSON ROMAN REYES, J.
The award of civil indemnity is mandatory and granted to the heirs of the victim without need of proof other than the commission of the crime. It requires only the establishment of the fact of death as a result of the crime and that the accused-appellant is responsible thereto.[56] However, in order to conform with the prevailing jurisprudence, the civil indemnity awarded to the heirs of victim must be raised to P75,000.00.[57]
	GR No. 182523 2012-09-15	PEOPLE v. EFREN LAURIO Y ROSALES LEONARDO-DE CASTRO, J.
The Court has often stated that factual findings of the trial court as regards its assessment of the witnesses' credibility are entitled to great weight and respect particularly when the Court of Appeals affirms the said findings, and will not be disturbed absent any showing that the trial court overlooked certain facts and circumstances which could substantially affect the outcome of the case.[20] It is the trial judge who had the opportunity to observe the witnesses' demeanor and deportment on the stand, and the manner in which they gave their testimonies.[21] The trial judge therefore is in a better position to determine the veracity of the witnesses' testimony.[22]
	GR No. 184500 2012-09-11	PEOPLE OF PIIILIPPINES v. WENCESLAO NELMIDA PEREZ, J.
As to penalty. Under Article 248 of the Revised Penal Code, the penalty imposed for the crime of murder is reclusion perpetua to death. There being neither aggravating nor mitigating circumstance, the penalty to be imposed upon appellants is reclusion perpetua for each count, pursuant to paragraph 2, Article 63[104] of the Revised Penal Code.[105]
	GR No. 175781 2012-03-20	PEOPLE v. FRANCISCA TALARO PERALTA, J.
Lolito Aquino's admission, and accused-appellants' positive identification of Raymundo Zamora and Rodolfo Duzon cannot be belied by accused-appellants' mere denial. It is established jurisprudence that denial and alibi cannot prevail over the witness' positive identification of the accused-appellants.[24] Moreover, accused-appellants could not give any plausible reason why Raymundo Zamora would testify falsely against them. In People v. Molina,[25] the Court expounded, thus: In light of the positive identification of appellant by the prosecution witnesses and since no ill motive on their part or on that of their families was shown that could have made either of them institute the case against the appellant and falsely implicate him in a serious crime he did not commit, appellant's defense of alibi must necessarily fail. It is settled in this jurisdiction that the defense of alibi, being inherently weak, cannot prevail over the clear and positive identification of the accused as the perpetrator of the crime. x x x[26] (Emphasis supplied)
	GR No. 192465 2011-06-08	PEOPLE v. ANGELITO ESQUIBEL Y JESUS CARPIO, J.
Further, we agree with the lower courts in appreciating treachery as a qualifying circumstance. The essence of treachery is the sudden and unexpected attack on an unsuspecting victim by the perpetrator of the crime, depriving the victim of any chance to defend himself or repel the aggression, thus, insuring its commission without risk to the aggressor and without any provocation on the part of the victim.[14] The sudden attack by Esquibel with a bladed weapon, with Baloloy's back against him, was undoubtedly treacherous. Baloloy was washing his hands outside his house when Esquibel appeared out of nowhere and stabbed him. Baloloy was unprepared and had no means to put up a defense. Such aggression insured the commission of the crime without risk on Esquibel.
	GR No. 178771 2011-06-08	PEOPLE v. ALBERTO ANTICAMARA Y CABILLO PERALTA, J.
In Criminal Case No. 4498-R, the award of civil indemnity is mandatory and granted to the heirs of the victim without need of proof other than the commission of the crime. [61] In People v. Quiachon, [62] even if the penalty of death is not to be imposed because of the prohibition in R.A. 9346, the civil indemnity of P75,000.00 is proper, because it is not dependent on the actual imposition of the death penalty but on the fact that qualifying circumstances warranting the imposition of the death penalty attended the commission of the offense. As explained in People v. Salome, [63] while R.A. No. 9346 prohibits the imposition of the death penalty, the fact remains that the penalty provided for by law for a heinous offense is still death, and the offense is still heinous. Accordingly, the award of civil indemnity in the amount of P75,000.00 is proper.
	GR No. 178272 2011-03-14	PEOPLE v. RODRIGO SALCEDO PERALTA, J.
The award of civil indemnity is mandatory and granted to the heirs of the victim without need of proof other than the commission of the crime.[51] The Court affirms the award of civil indemnity given by the trial court and the CA in the amount of PhP50,000.00.
	GR No. 189580 2011-02-09	PEOPLE v. ALVIN DEL ROSARIO NACHURA, J.
The age-old rule is that the task of assigning values to the testimonies of witnesses and weighing their credibility is best left to the trial court which forms first-hand impressions as witnesses testify before it. It is thus no surprise that findings and conclusions of trial courts on the credibility of witnesses enjoy, as a rule, a badge of respect, for trial courts have the advantage of observing the demeanor of witnesses as they testify.[16] Further, factual findings of the trial court as regards its assessment of the witnesses' credibility are entitled to great weight and respect by this Court, particularly when the CA affirms the said findings, and will not be disturbed absent any showing that the trial court overlooked certain facts and circumstances which could substantially affect the outcome of the case.[17]
	GR No. 186420 2009-08-25	PEOPLE v. SAMUEL ANOD NACHURA, J.
As to damages, we held in People of the Philippines v. Judito Molina and John Doe, and Joselito Tagudar,[14] that when death occurs due to a crime, the following damages may be awarded: (1) civil indemnity ex delicto for the death of the victim; (2) actual or compensatory damages; (3) moral damages; (4) exemplary damages; and (5) temperate damages.

PEOPLE v. JUDITO MOLINA