**Facts:**
On August 17, 1990, at about 4:30 PM, Charlie Fernandez, an ambulant vendor, was fatally stabbed on M. de la Fuente Street, Manila, by the accused, David Salvatierra y Eguia, and two unidentified accomplices. Charlie managed to walk home and inform his father before collapsing. He was immediately taken to the hospital and operated on, but died the next day due to hemorrhage caused by the stab wounds.
Eyewitness Milagros Martinez, who was close by, witnessed the assault but delayed reporting it due to fear. Charlie’s father, Marciano Fernandez, reported the incident to the police, naming Salvatierra as a suspect. Salvatierra was arrested on November 15, 1990, during a commotion and subsequently identified by Martinez in a police lineup.
Salvatierra was charged with murder and pleaded not guilty, providing an alibi that he was at home at the time of the crime. He contested the legality of his arrest and the credibility of the eyewitness.
**Issues:**
1. Was the arrest, investigation, and detention of Salvatierra carried out in violation of his constitutional rights?
2. Did the killing of Charlie Fernandez involve treachery aggravating the crime to murder?
3. Was the testimony of Milagros Martinez credible and sufficient to convict Salvatierra?
**Court’s Decision:**
1. **Legality of Arrest and Constitutional Rights:**
– The Court ruled that although Salvatierra’s arrest for the murder, following a minor offense arrest without a warrant, was potentially illegal, he waived the right to contest it by not objecting before entering his plea. Jurisdiction was validly obtained as Salvatierra voluntarily participated in the trial.
– The Court also found no grounds to dismiss the case based on the absence of counsel during the police lineup and booking. These procedural defects did not invalidate subsequent legal proceedings nor did they sufficiently prejudice Salvatierra’s rights given other substantial evidence.
2. **Treachery:**
– Treachery was affirmed. Salvatierra and his accomplices’ sudden attack left the victim defenseless, ensuring no risk to themselves. Though some accomplices did not actively participate, the coordination and surprise element met the criteria for treachery.
3. **Credibility of Eyewitness Testimony:**
– The Court held that Milagros Martinez’s identification of Salvatierra was consistent and reliable. Despite minor inconsistencies in her testimony, they were deemed trivial and did not affect her credibility. Her proximity to the incident and the fact it took place in broad daylight reinforced the accuracy of her identification.
The Court upheld Salvatierra’s conviction for murder with the penalty of reclusion perpetua and indemnity to the victim’s heirs.
**Doctrine:**
– The estoppel principle indicates that failure to contest a warrantless arrest before pleading constitutes a waiver of any objection.
– Treachery involves methods that ensure execution without risk to the offender, and sudden attacks can qualify as treacherous even in a frontal attack.
– Credibility assessments of eyewitnesses may accommodate minor inconsistencies as they can indicate genuineness.
**Class Notes:**
– **Estoppel in Criminal Procedure:** Objections to jurisdiction over the person due to a warrantless arrest must be made before entering a plea.
– **People v. Manzano, 248 SCRA 239, 245 (1995)**
– **Treachery:** An attack qualifies as treacherous if it is executed in a manner that guarantees execution without risk to the attacker.
– **Article 248, Revised Penal Code (Murder definition)**
– **Credibility of Witnesses:** Minor inconsistencies in testimony may enhance credibility by indicating the witness is not rehearsed.
– **People v. Montante, 192 SCRA 483 (1990)**
**Historical Background:**
During the late 1980s and early 1990s, street crime in the Philippines, particularly in urban areas like Manila, was a significant concern. The period also saw heightened activities of gangs such as “Bahala Na Gang,” notorious for violent crimes. This case exemplifies the struggles in law enforcement concerning witness cooperation and procedural adherence amidst pervasive violence and fear in urban communities. The decision reinforced procedural principles and the reliability of eyewitness testimony in the justice system against a backdrop of persistent criminality.
Leave a Reply