CASE: People v.
De Guzman
DATE: February 4, 2009
GR NO: 173477
FACTS:
● Franco de Guzman, the appellant, faced murder charges for killing Dr. Fidelito Manaois. The incident
took place on November 14, 2003, in Brgy. Guiguilonen, Mangaldan, Pangasinan. The appellant was
armed with a handgun and used a motorcycle to carry out the crime. He shot Dr. Manaois multiple times,
resulting in the victim's death. The appellant was arrested on December 15, 2003, and incarcerated at the
Bureau of Jail Management and Penology (BJMP) in Dagupan City.
● During the trial, witnesses included the appellant's wife, a pedicab driver, and an eyewitness who
worked
with the victim. The Regional Trial Court (RTC) convicted the appellant of murder and sentenced him
to reclusion perpetua. The Court of Appeals later modified the sentence to death.
ISSUE:
● Whether or not did the prosecution meet the quantum of proof required to overcome the constitutional
presumption of innocence of the appellant, (2) did the trial court err in dismissing the appellant's defense
of denial and alibi, (3) did the trial court err in giving credence to the testimonies of the prosecution
witnesses, (4) were treachery and evident premeditation present in this case, and (5) was the out-of-court
identification of the appellant flawed.
RULING:
● The Court upheld the Court of Appeals' ruling, confirming the appellant's guilt for murder and
sentencing
him to reclusion perpetua. The appellant was also ordered to compensate the victim's heirs with P75,000
in civil indemnity, P50,000 in moral damages, and P25,000 in exemplary damages, all accruing interest
at the legal rate of six percent (6%) per annum from the date of the decision until fully paid.
● The prosecution successfully met the burden of proof required for the appellant's conviction. The trial
court and Court of Appeals properly dismissed the alibi defense. The trial court's determinations
regarding the credibility of witnesses were upheld. The case involved treachery, as the victim was
attacked suddenly and unexpectedly, leaving no opportunity to resist or escape. However, evident
premeditation was not established due to insufficient evidence regarding when the appellant decided to
commit the crime and actions indicating his intent. The eyewitness's out-of-court identification of the
appellant was valid; the delay in identification was justifiable given the witness's fear for his safety
