The appellant Danny Delos Santos was convicted of murdering Rod Flores with the qualifying circumstance of treachery. Two eyewitnesses testified that they saw the appellant emerge from behind Flores and stab him multiple times until he died. The appellant claimed he was at his aunt's house at the time of the murder. The court found the inconsistencies in the eyewitness testimony to be minor details that did not affect the substance of their claims. The court affirmed the conviction, finding that a sudden and unexpected attack from behind without provocation demonstrated treachery, and motive is not required to prove murder where positive eyewitness identification is provided.
The appellant Danny Delos Santos was convicted of murdering Rod Flores with the qualifying circumstance of treachery. Two eyewitnesses testified that they saw the appellant emerge from behind Flores and stab him multiple times until he died. The appellant claimed he was at his aunt's house at the time of the murder. The court found the inconsistencies in the eyewitness testimony to be minor details that did not affect the substance of their claims. The court affirmed the conviction, finding that a sudden and unexpected attack from behind without provocation demonstrated treachery, and motive is not required to prove murder where positive eyewitness identification is provided.
The appellant Danny Delos Santos was convicted of murdering Rod Flores with the qualifying circumstance of treachery. Two eyewitnesses testified that they saw the appellant emerge from behind Flores and stab him multiple times until he died. The appellant claimed he was at his aunt's house at the time of the murder. The court found the inconsistencies in the eyewitness testimony to be minor details that did not affect the substance of their claims. The court affirmed the conviction, finding that a sudden and unexpected attack from behind without provocation demonstrated treachery, and motive is not required to prove murder where positive eyewitness identification is provided.
The appellant Danny Delos Santos was convicted of murdering Rod Flores with the qualifying circumstance of treachery. Two eyewitnesses testified that they saw the appellant emerge from behind Flores and stab him multiple times until he died. The appellant claimed he was at his aunt's house at the time of the murder. The court found the inconsistencies in the eyewitness testimony to be minor details that did not affect the substance of their claims. The court affirmed the conviction, finding that a sudden and unexpected attack from behind without provocation demonstrated treachery, and motive is not required to prove murder where positive eyewitness identification is provided.
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PEOPLE OF THE PHILIPPINES, appellee, vs.
DANNY DELOS SANTOS Y
FERNANDEZ, appellant. G.R. No. 135919. May 9, 2003 FACTS: ● Upon one of the statements of the witness (Marcelino De Leon), he saw that Rod Flores was drinking gin with some men. As he was about to fetch water, he suddenly sees appellant emerged from the back of Flores and stabbed him multiple times and ceased only after he saw him dead. ● Dr. Caballero declared that Flores suffered 21 stab wounds and 11of which were fatal and said that it was possible that appellant was behind Flores considering the stab wounds inflicted in his back. ● But appellant denied the accusation and said that on the exact time, he was in his Auntie’s house 40 meters away from the scene of the crime and it was seconded by a certain Sonny Bautista and watched television. ● Appellant also said that earlier that day, they met when he is fetching water but there is no altercation between them hence, he couldn’t understand why there are testimonies against him. But the appellant contends that there were inconsistencies as to the testimony of the witness and they failed to prove that appellant has a motive to kill Flores. ● Trial court held that Danny Delos Santos found guilty of the crime of murder with the qualifying circumstance of treachery. ISSUE: ● Whether or not the trial court erred in finding the accused guilty of murder with qualifying circumstance of treachery based on the testimony of the alleged eyewitness since there was inconsistencies in them. RULING: ● The court said that the inconsistencies were understandable since they are drinking gin at the time the crime happened. Many the time the court ruled that inconsistencies in the testimony of witnesses when referring only to minor details and collateral matters do not affect the substance of their declaration, their veracity, or the weight of their testimony. What is important is that the two witnesses were one in saying that it was the appellant who stabbed Flores with a knife. ● When appellant argues that since the witnesses said that there was no altercation between him and Flores, it now follows that there is no motive to kill but the court said no! Proof of motive is not indispensable for a conviction, particularly where the accused is positively identified by an eyewitness and his participation is adequately established. ● Therefore, the Court affirmed the Trial Courts decision since the prosecution was able to establish that appellant's attack on Flores was from behind without any slightest provocation on his part and that it was sudden and unexpected- a clear case of treachery. Where the victim was totally unprepared for the unexpected attack from behind with no weapon to resist it, the stabbing could only be described as treacherous. There being treachery, appellant's conviction for murder is in order.
Robert Bowie Johnson, Jr. v. Kalman R. Hettleman, University of Maryland, School of Social Work Luther Starnes, Department of Employment and Training Carl Snowden, the Annapolis and Anne Arundel Community Action Agency Emmett Burns Dr., Region Vii Director, the N.A.A.C.P. National Organization for Women the American Public Welfare Association, and Chauncey Alexander National Association of Social Workers Sylvia Gonzales Edward T. Weaver, Executive Director, the American Public Welfare Association Peter Slavin, Editor, Washington Report, the American Public Welfare Association, 812 F.2d 1401, 4th Cir. (1987)