**Facts:**
1. **Incident Date:** On May 25, 1997, around 4:00 PM at Sitio Candulungon, Barangay Cabay, Balangkayan, Eastern Samar.
2. **Victim and Witnesses:** Eladio Globio, Sr., was ambushed by Wilfredo Gunda and unidentified accomplices. Eladio Jr. (the victim’s son) and Teofilo Ambal, Jr. witnessed the crime.
3. **Assault Details:** Wilfredo Gunda and his companions waylaid Eladio Sr. Eladio Jr., 10 meters ahead, fled when the attack began. Armed with a wooden pole, Wilfredo struck Eladio Sr.’s head, while accomplices restrained him. Wilfredo then stabbed Eladio several times using a bolo knife (depang).
4. **Aftermath & Police Action:** Eladio Jr. reported the crime to the police the following day after escaping. The victim’s body was discovered with multiple stab wounds.
5. **Charge Filed:** On July 31, 1997, an Information was filed charging Wilfredo Gunda and the John Does with murder. The charge included aggravating factors of an uninhabited place and superior strength.
6. **Trial and Defense:** Arraigned on September 10, 1997, Wilfredo pleaded not guilty, claiming an alibi of being at Barangay Camada gathering rattan poles at the time of the incident.
**Procedural Posture:**
1. **RTC Decision:** On May 20, 2005, the Regional Trial Court found Wilfredo guilty of murder, sentencing him to death, and ordered to pay damages totaling P125,000. Testimonies from Eladio Jr. and Ambal, as well as post-mortem results, pivotal in conviction.
2. **Court of Appeals (CA):** Affirmed RTC’s findings on March 30, 2010, with modification—reduced the penalty to reclusion perpetua as treachery could not both qualify and aggravate the crime.
3. **Supreme Court Decision:** On further appeal, the Supreme Court affirmed the appellate court’s modified decision, emphasizing the proper application of principles surrounding treachery and penalties under the Revised Penal Code.
**Issues:**
1. Whether Wilfredo Gunda was guilty beyond reasonable doubt of murder.
2. Whether the crime was attended by treachery warranting the classification as murder.
3. The determination of the appropriate penalty, considering aggravating and mitigating circumstances.
**Court’s Decision:**
1. **Guilt:** Supreme Court upheld the findings of lower courts, convicting Wilfredo of murder with credible eyewitness testimony and corroborative autopsy results. Alibi defense was discredited given the proximity between the crime scene and the alleged location of Wilfredo.
2. **Treachery as Qualifying Circumstance:** Defined the attack’s treacherous nature—unarmed victim, unexpectedly assaulted, eliminating any defense opportunity, thereby qualifying the killing as murder.
3. **Penalty Application:** Affirmed the imposition of reclusion perpetua without parole due to the absence of additional aggravating circumstances beyond treachery.
4. **Damages Awarded:** Adjusted damages—P75,000 civil indemnity, P50,000 moral damages, and increased exemplary to P30,000. Additional temperate damages of P25,000 were awarded due to unascertained actual damages with interest applied at 6% per annum from judgment finality until fully paid.
**Doctrine:**
– **Treachery:** It qualifies a killing to murder when the method of execution is deliberate, unanticipated, and strips the victim of defense.
– **Conspiracy:** While it establishes collective criminal liability, it isn’t a circumstance that affects the gravity of penal consequences.
– **Dual Function Principle:** A qualifying circumstance like treachery cannot simultaneously be aggravating for penalty enhancement.
**Class Notes:**
– **Murder Qualifying Factors:** Treachery elevates a homicide to murder by removing defense possibilities from the victim.
– **Penalty Structure:** Reclusion perpetua applies absent additional aggravating circumstances.
**Historical Background:**
This case illustrates the application of treachery in classifying murder within Philippine legal jurisprudence. The ruling reinforces jurisprudence that while conspiracy indicates joint liability, it does not alter penalty standards individually. This reflects careful judicial interpretation in balance with procedural and substantive legal precepts established in the Revised Penal Code and subsequent legal reforms advancing penal policy.
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