In People v. Geron, the Supreme Court affirmed the conviction of Joven Geron for murder, emphasizing the reliability of eyewitness testimony and the presence of treachery in the commission of the crime. The Court underscored that a witness’s consistent and categorical identification of the accused, absent any ill motive, holds significant weight. This ruling clarifies how Philippine courts evaluate eyewitness accounts in conjunction with the legal definition of treachery to establish guilt beyond a reasonable doubt in murder cases, reinforcing the importance of credible testimony in criminal proceedings.

Sudden Assault in Sariaya: Did Treachery Seal the Fate of Willy Sison?

The case revolves around the events of March 9, 2004, in Barangay Bignay I, Sariaya, Quezon, where Willy Sison was fatally shot. According to the prosecution, Joven Geron, along with his brothers, arrived at the Sison’s store on a motorcycle. Joven alighted and unexpectedly opened fire on Willy, who was counting money. Diomedes Sison, Willy’s brother, witnessed the event and identified Joven as the shooter. This identification became a central point in the legal proceedings that followed.

At trial, Joven Geron presented an alibi, claiming he was in Mandaluyong City at the time of the shooting. However, the Regional Trial Court (RTC) and later the Court of Appeals (CA) found his alibi unconvincing, especially when weighed against the positive identification by Diomedes. The RTC convicted Joven of murder and attempted homicide, a decision the CA affirmed. Joven then appealed to the Supreme Court, questioning the credibility of Diomedes’ testimony and reiterating his alibi.

The Supreme Court, in its analysis, highlighted several critical elements. First, it addressed the requirements for proving murder, stating:

The elements of murder that the prosecution must establish are: (1) that a person was killed; (2) that the accused killed him or her; (3) that the killing was attended by any of the qualifying circumstances mentioned in Article 248 of the Revised Penal Code; and (4) that the killing is not parricide or infanticide.

The prosecution successfully established these elements, particularly through Diomedes’ eyewitness account, which the Court found to be both clear and consistent. The Court noted that Diomedes’ testimony was consistent with his initial sworn affidavits and statements during the preliminary investigation. This consistency reinforced the credibility of his identification of Joven as the perpetrator.

Furthermore, the Court emphasized the significance of positive identification by a credible witness, especially when there is no apparent motive for the witness to falsely accuse the defendant. The Court cited the principle that:

Positive identification when categorical and consistent and without any showing of ill motive on the part of the eyewitness testifying on the matter, prevails over a denial which, if not substantiated by clear and convincing evidence, is negative and self-serving evidence undeserving of weight in law. They cannot be given greater evidentiary value over the testimony of credible witnesses who testify on affirmative matters.

Building on this principle, the Court dismissed Joven’s alibi, especially in light of rebuttal testimony placing him near the scene of the crime around the time it occurred. The Court then turned to the qualifying circumstance of treachery. Treachery, under Article 14, paragraph 16 of the Revised Penal Code, is defined as the employment of means, methods, or forms in the execution of a crime that ensure its commission without risk to the offender arising from the defense the offended party might make.

In this case, the Court found that treachery was indeed present. The suddenness of the attack, with Joven alighting from the motorcycle and immediately firing at Willy, demonstrated that Willy had no chance to defend himself. The Court observed that:

The element of treachery attended the shooting against Willy. Joven suddenly alighted from the motorcycle, pointed his gun at Willy and immediately shot him. The attack was sudden and unexpected. Willy, who was unarmed, had no inkling that he would be shot such that he did not have any real chance to defend himself.

The legal framework within which the Court operated also included the appropriate penalty for murder. Article 248 of the Revised Penal Code prescribes the penalty of reclusion perpetua to death for murder. Given the absence of any aggravating circumstances, the Court affirmed the imposition of reclusion perpetua. However, the Court also modified the monetary awards, increasing the civil indemnity, moral damages, and exemplary damages to P100,000.00 each, aligning with prevailing jurisprudence. In addition, the Court imposed an interest rate of six percent (6%) per annum on all monetary awards from the date of finality of the decision until fully paid.

In assessing the conviction for attempted homicide against Diomedes, the Court agreed with the lower courts that Diomedes was able to evade the full force of Joven’s attack. Diomedes’ awareness and ability to escape distinguished his case from that of his brother, where the suddenness of the attack constituted treachery. Since the injuries sustained by Diomedes were not fatal and his escape prevented further attacks, the Court determined that the crime remained at the attempted stage. As stated by the Court of Appeals:

… a felony is “attempted” when the offender commences the commission of a felony directly by overt acts, and does not perform all the acts of execution which should produce the felony by reason of some cause or accident other than his own spontaneous desistance. In the present case, shots were fired by accused-appellant towards Diomedes but none of the injuries he sustained, as a result – by testimony of Dr. Catarroja – were fatal. In addition, accused-appellant was prevented from further attacking Diomedes by the simple expedient of the latter’s escape. Ergo, this case is clearly still within the attempted stage of the execution of the crime of homicide.

The attempted homicide conviction was therefore upheld, with the penalty appropriately applied according to the Indeterminate Sentence Law.

FAQs

What was the key issue in this case?	The key issue was whether Joven Geron was guilty of murder and attempted homicide based on eyewitness testimony and the presence of treachery. The Supreme Court had to determine if the evidence presented by the prosecution was sufficient to prove his guilt beyond a reasonable doubt.
What is treachery and why was it important in this case?	Treachery is a qualifying circumstance in murder where the offender employs means to ensure the commission of the crime without risk to themselves. It was important because it elevated the crime from homicide to murder, carrying a higher penalty.
Why was the eyewitness testimony of Diomedes Sison so crucial?	Diomedes Sison was the lone eyewitness who identified Joven Geron as the shooter. His testimony was deemed credible because it was consistent with his initial statements and he had no apparent motive to falsely accuse Joven.
What was Joven Geron’s defense and why was it rejected?	Joven Geron’s defense was an alibi, claiming he was in Mandaluyong City at the time of the shooting. It was rejected because the prosecution presented a rebuttal witness placing him near the crime scene, and his alibi did not outweigh the positive identification by the eyewitness.
What is the penalty for murder under Philippine law?	Under Article 248 of the Revised Penal Code, the penalty for murder is reclusion perpetua to death. The specific penalty depends on the presence of aggravating or mitigating circumstances.
What were the monetary damages awarded in this case?	The Supreme Court increased the awards to P100,000.00 each for civil indemnity, moral damages, and exemplary damages. Additionally, an interest rate of six percent (6%) per annum was imposed on all monetary awards from the date of finality of the decision until fully paid.
What is attempted homicide and why was Joven Geron also convicted of this crime?	Attempted homicide occurs when the offender commences the commission of homicide but does not perform all the acts of execution due to some cause other than their own spontaneous desistance. Joven Geron was convicted because he shot at Diomedes, but Diomedes survived and escaped, preventing the completion of the crime.
Was Joven Geron eligible for parole after this decision?	No, the Supreme Court specifically stated that Joven Geron was not eligible for parole, pursuant to Section 3 of Republic Act No. 9346, given his conviction for murder.

The Supreme Court’s decision in People v. Geron reinforces the importance of credible eyewitness testimony and the rigorous application of the elements of murder, including treachery. This case serves as a reminder of the severe consequences of violent crime and the critical role of the courts in ensuring justice for victims and their families. The decision provides legal clarity regarding the standards for establishing guilt in murder cases and sets a precedent for future adjudications.

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. Joven Geron y Yema, G.R. No. 208758, August 24, 2016