In a criminal case, a guilty verdict depends upon proof beyond reasonable doubt. The Supreme Court ruled that Rodolfo Sison was guilty beyond reasonable doubt of murder due to treachery. This means that the unexpected and sudden nature of his attack on the victim made it impossible for the victim to defend himself, thus elevating the crime from homicide to murder. This underscores how the element of surprise in a violent act can significantly alter the legal consequences for the perpetrator.

Stones, Shadows, and a Shot: Did Sison’s Attack Constitute Murder?

The case revolves around the events of November 25, 1993, in Lingayen, Pangasinan. Bernabe dela Cruz, roused by stones hitting his house, confronted Rodolfo Sison and Corleto Sendaydiego outside. Unexpectedly, Sison drew a gun and shot Dela Cruz, who later died from his injuries. Sison was charged with murder. The key legal question: Did the shooting involve treachery, thus qualifying it as murder, or was it simply homicide? The trial court convicted Sison of murder, a decision affirmed by the Court of Appeals (CA).

The Supreme Court (SC) meticulously reviewed the evidence, focusing on the testimonies of eyewitnesses. Bernadette dela Cruz, the victim’s daughter, testified that she saw Sison shoot her father. Her account was corroborated by her siblings, Bernie and Bernalyn, as well as the victim’s widow, Lydia. The SC emphasized the trial court’s advantage in assessing witness credibility. This advantage stems from the trial court’s opportunity to observe the witnesses’ demeanor while testifying. The consistency and clarity of the eyewitness accounts played a crucial role in establishing Sison’s guilt beyond a reasonable doubt.

Sison’s defense rested on denial, claiming Sendaydiego was the shooter. However, the SC found his denial unconvincing, particularly in light of the positive identification by multiple witnesses. The court reiterated that denial is a weak defense, especially when contradicted by credible eyewitness testimony. His admission that he did not surrender to the police further undermined his credibility. This demonstrated a consciousness of guilt, which is contrary to being innocent.

A crucial element in the case was whether the killing was attended by treachery, as defined in Article 14(6) of the Revised Penal Code:

when the offender commits any of the crimes against the person, 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.

The SC emphasized that treachery involves a sudden, unexpected attack that gives the victim no chance to defend themselves. The evidence showed that Sison shot Dela Cruz without warning, from a short distance. Because Dela Cruz did not have time to defend himself, he had no means to retaliate. This lack of opportunity to resist was essential for concluding treachery was proven.

While the prosecution argued evident premeditation, the SC disagreed. Evident premeditation requires proof of planning and preparation to kill, as well as sufficient time for the accused to reflect on their actions. In this case, the SC found the time between the stoning incident and the shooting was too short to establish premeditation. Thus, that aggravating circumstance was not considered.

The conviction for murder was upheld due to the presence of treachery. Murder carries a penalty of reclusion perpetua to death. Absent any mitigating or aggravating circumstances, Sison’s sentence of reclusion perpetua was deemed appropriate. In addition, the court discussed the importance of proving actual damages in order to obtain them, but awarded temperate damages when proof was lacking.

The SC modified the award of damages. While the lower courts awarded P75,000.00 in actual damages, the SC found only P6,030.00 was supported by documentary evidence. However, to avoid an unfair outcome, the SC awarded P25,000.00 in temperate damages. This was meant to avoid a scenario in which a party able to provide a very minimal level of documented damages might be penalized as compared to a party who provides none.

Civil indemnity of P50,000.00 and moral damages of P50,000.00 were affirmed, the latter recognizing the mental anguish suffered by the victim’s family. Exemplary damages of P25,000.00 were also deemed proper, given the finding of treachery. These amounts were meant to, in some way, make up for the tremendous loss experienced by the family of the victim. Such monetary awards are common in criminal cases in the Philippines.

FAQs

What was the key issue in this case?	The key issue was whether the killing of Bernabe dela Cruz constituted murder, due to the presence of treachery, or simply homicide. The court had to determine if the suddenness of the attack qualified as treachery.
What is treachery under Philippine law?	Treachery, as defined in the Revised Penal Code, is when the offender commits a crime against a person using means that directly and specially ensure its execution without risk to the offender from any defense the victim might make. It is marked by the element of surprise and defenselessness.
What evidence did the prosecution present to prove Sison’s guilt?	The prosecution presented eyewitness testimonies from the victim’s children and widow, all of whom positively identified Sison as the shooter. The testimonies provided a consistent account of the events leading to the shooting and the shooting itself.
What was Sison’s defense?	Sison’s defense was denial. He claimed that his co-accused, Sendaydiego, was the shooter. He tried to paint a picture in which he was merely present at the scene, but not involved.
Why did the Supreme Court uphold the conviction for murder?	The Supreme Court upheld the conviction because the prosecution successfully proved treachery. Sison’s sudden and unexpected attack on Dela Cruz, who was unarmed and defenseless, qualified as treachery, elevating the crime to murder.
What is the difference between homicide and murder?	Homicide is the killing of one person by another, without any qualifying circumstances. Murder is homicide qualified by certain circumstances, such as treachery, evident premeditation, or cruelty, which increase the severity of the crime.
What damages were awarded to the victim’s heirs in this case?	The Supreme Court awarded the heirs civil indemnity (P50,000.00), moral damages (P50,000.00), temperate damages (P25,000.00), and exemplary damages (P25,000.00). Temperate damages were awarded in place of actual damages due to insufficient documentary evidence to prove them.
What is the significance of eyewitness testimony in criminal cases?	Eyewitness testimony is a significant piece of evidence, especially when the eyewitness is considered credible by the trial court. When the credibility is clear and the testimony reliable, that carries heavy weight in cases.
What is the penalty for murder in the Philippines?	Under the Revised Penal Code, as amended, the penalty for murder is reclusion perpetua to death. The specific penalty depends on the presence of mitigating or aggravating circumstances.

This case highlights the importance of understanding the elements that differentiate homicide from murder, particularly the concept of treachery. It serves as a reminder of how the manner in which a crime is committed can significantly impact the legal consequences for the accused.

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. RODOLFO SISON, G.R. No. 172752, June 18, 2008