327 Cases Penned by Associate Justice Amy Lazaro-Javier: 2025 Bar Examination
Can a sudden, swift, and unprovoked attack using a bladed
weapon elevate a simple killing to murder based on treachery, even without
evident premeditation?
People of the Philippines v. Marcelino Saltarin y Talosig, G.R. No. 223715, June 03, 2019
FACTS:
On the night of November 6, 2011, in Manila, Joval Benitez
de Jesus was sitting with 15-year-old Gerry Narido outside a junk shop.
Marcelino Saltarin y Talosig approached them and asked for coins. The victim
gave him coins, but when Saltarin asked for more, the victim refused. After
initially leaving, Saltarin returned, handed a cigarette to the victim, and
then, in an unexpected and unprovoked manner, stabbed him once in the chest
with a knife. The wound was fatal, piercing the victim's heart, leading to his
immediate death.
The prosecution relied heavily on the testimony of Gerry
Narido, the sole eyewitness. Narido vividly recounted how Saltarin delivered
the fatal blow while seated next to the victim. Despite the defense's claim
that Saltarin acted in self-defense after an altercation with the victim, the
trial court gave more weight to Narido's clear and consistent testimony.
The Regional Trial Court (RTC) convicted Saltarin of murder,
appreciating the qualifying circumstance of treachery. However, the court did
not consider evident premeditation due to a lack of proof that Saltarin had
planned the killing beforehand. The RTC sentenced Saltarin to reclusion
perpetua and ordered him to pay damages to the victim’s family.
On appeal, Saltarin argued that it was impossible for Narido
to have accurately identified him because the incident occurred at night.
Additionally, he claimed that Narido had inconsistencies in his testimony.
However, the Court of Appeals upheld the trial court’s ruling, modifying the
damages awarded to the victim’s family by increasing the amounts.
ISSUE BEFORE THE SUPREME COURT:
Did the Court of Appeals err in affirming Saltarin’s
conviction for murder, especially with the modification of the penalty and
monetary awards?
SUPREME COURT RULING:
The Supreme Court found no merit in the appeal. It ruled
that the lower courts correctly appreciated the qualifying circumstance of
treachery. The sudden and unexpected attack on the victim, who was unarmed and
unprepared, made it impossible for him to defend himself, thereby qualifying
the killing as murder. Treachery is present when the attack is executed in such
a way that the victim has no opportunity to defend himself or retaliate.
Although the defense argued self-defense, the Court found
that Saltarin’s claim was unsubstantiated. Furthermore, the Court affirmed the
factual findings of the trial court, which are accorded great respect,
particularly when they are consistent with the testimony of witnesses and the
physical evidence.
DISPOSITIVE PORTION:
The Supreme Court affirmed the decision of the Court of
Appeals with modifications. Marcelino Saltarin y Talosig was found guilty of
murder and sentenced to reclusion perpetua. He was ordered to pay Php
13,500.00 as actual damages, Php 75,000.00 as civil indemnity, Php 75,000.00 as
moral damages, and Php 75,000.00 as exemplary damages, all of which will earn
6% interest per annum until fully paid.
In cases involving treachery, should the courts give more
weight to the suddenness of the attack or the intent behind it?
IMPORTANT DOCTRINES:
- Treachery
– This exists when the attack is executed in a swift, deliberate, and
unexpected manner, ensuring the victim has no chance to defend themselves.
In this case, Saltarin’s sudden and unprovoked stabbing of the victim
while seated beside him constituted treachery.
- Denial
as a weak defense – Courts view denial with disfavor, especially when
it is unsupported by convincing evidence and when there is strong and
consistent positive identification of the accused by witnesses.
- Credibility
of eyewitness testimony – The testimony of an eyewitness who was
present at the crime scene and who identifies the assailant with certainty
is given great weight, particularly when corroborated by physical
evidence.
This case falls under Criminal Law.
From <https://chatgpt.com/c/66f00e04-47e8-800a-ace4-4fe40f73acb3>
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Read the full text here
🎓 Welcome, future
lawyers and bar exam warriors!
In this video, we’ll explore a landmark criminal law
jurisprudence that dissected the essence of treachery in murder cases.
We’ll go through important doctrines extracted from the
Supreme Court decision in People of the Philippines vs. Marcelino Saltarin y
Talosig, G.R. No. 223715, promulgated on June 3, 2019. This
video aims to help law students and bar reviewees better recall,
understand, and master critical rulings in this case.
NATURE OF THE CASE: Criminal Law – Murder
PARTIES:
- Plaintiff-Appellee:
People of the Philippines
- Accused-Appellant: Marcelino Saltarin y Talosig
CASE SUMMARY:
The accused stabbed the victim, Joval de Jesus, in a swift
and unexpected manner over a coin dispute. The issue revolved around whether
the killing was qualified by treachery, and if evident premeditation was
present. The RTC and CA convicted him. The Supreme Court affirmed the murder
conviction, appreciating treachery but not evident premeditation.
💡 Can a single,
impulsive act driven by rage still be classified as murder when done in a
calculated, treacherous manner?
📚 10 IMPORTANT DOCTRINES
(Factual and Digestible)
- Treachery
Qualifies a Killing as Murder
If the attack is sudden, deliberate, and unexpected, rendering the victim defenseless, it is considered treacherous.
📖 [SC Decision, People v. Saltarin, G.R. No. 223715] - Victim’s
Inability to Defend Himself is Key
Treachery exists when the mode of attack ensures the offender’s safety while disabling the victim’s ability to retaliate.
📖 [SC Decision, citing People v. Pulgo] - Eyewitness
Credibility Trumps Minor Inconsistencies
The testimony of a single eyewitness, if credible and direct, is sufficient for conviction despite inconsistencies in minor details.
📖 [SC Decision, citing People v. Regaspi] - Relationship
Doesn’t Disqualify a Witness
A witness related to or close to the victim is not automatically biased; such relation can actually explain the pursuit of justice.
📖 [SC Decision] - No
Need for "Without Parole" Tag Absent Aggravating Circumstances
The phrase “without eligibility for parole” is not required if the death penalty was not applicable.
📖 [SC Decision, citing A.M. 15-08-02-SC] - Evident
Premeditation Requires Specific Elements
There must be proof of planning, persistence, and time for reflection before committing the crime. None was proven in this case.
📖 [SC Decision, citing People v. Isla] - Denial
is a Weak Defense
Denial and alibi cannot prevail over positive and direct identification.
📖 [SC Decision, citing People v. Peteluna] - Being
Present at Crime Scene Weakens Alibi
Saltarin admitted being at the crime scene, contradicting his defense of non-involvement.
📖 [SC Decision] - Minor’s
Testimony Can Be Fully Credible
Narido, a 15-year-old, was found credible and consistent, despite being emotionally shaken during the event.
📖 [SC Decision] - Damages
Follow Jurisprudential Guidelines
The SC awarded ₱75,000 each for civil, moral, and exemplary damages, plus ₱13,500 actual damages, with 6% interest.
📖 [SC Decision, citing People v. Jugueta]
❓ FREQUENTLY ASKED QUESTIONS
(FAQs)
1. What makes a killing “murder” under Philippine law?
➡ Murder involves a killing
qualified by circumstances like treachery, evident premeditation, or cruelty
under Article 248 of the RPC.
2. Is treachery enough to convict for murder?
➡ Yes. Treachery alone can
qualify a killing as murder if proven.
3. Can a child witness be credible in court?
➡ Absolutely. As in this case, a
minor’s clear and consistent testimony can lead to conviction.
4. Why wasn’t evident premeditation appreciated?
➡ There was no showing of a
prior plan or sufficient time for reflection before the attack.
5. Why was “without eligibility for parole” not stated in
the penalty?
➡ Because no aggravating
circumstance warranted the death penalty under RA 9346.
⚖️ CASE: People v.
Saltarin, G.R. No. 223715, June 3, 2019
📢 DISCLAIMER: This
video is for educational purposes only. It does not guarantee infallibility.
Content was generated using premium AI.
🛎️ LIKE, COMMENT, and
SAVE this post for future reference!
What do YOU think—should momentary rage excuse a treacherous
killing from being classified as murder?
🎓 Welcome to this
short legal quizzer crafted especially for law students and bar reviewees!
This quizzer focuses on a landmark Criminal Law case:
People of the Philippines vs. Marcelino Saltarin y
Talosig,
G.R. No. 223715, promulgated on June 3, 2019.
Nature of the Case: Murder (Criminal Law)
Parties:
- Plaintiff-Appellee:
People of the Philippines
- Accused-Appellant: Marcelino Saltarin y Talosig
Brief Summary:
The case revolves around the fatal stabbing of Joval de
Jesus by the accused following a coin-related altercation. A 15-year-old
eyewitness testified that the killing was sudden and unprovoked. The trial
court and the Court of Appeals convicted the accused of murder,
appreciating treachery but not evident premeditation. The Supreme
Court affirmed the ruling, holding that the mode of attack rendered the
victim defenseless.
📝 Answer key will be
provided at the end of the video. Let’s begin!
🔥 10 EASY DIFFICULTY HOTS
(Higher Order Thinking Skills) MULTIPLE CHOICE QUESTIONS:
1. What was the main reason the Supreme Court upheld
the murder conviction of Marcelino Saltarin?
A. The attack was committed in public
B. The weapon used was illegal
C. The attack was treacherous and left the victim
defenseless
D. The victim was a public official
2. Which of the following best describes “treachery”
as applied in the case?
A. When the attacker used poison
B. When the victim had no time to defend himself from a
sudden attack
C. When the attacker used a gun
D. When the crime was witnessed by a child
3. Why did the Court reject evident premeditation in
this case?
A. The accused admitted the crime
B. There was no proof of planning or reflection before the
killing
C. The knife was not recovered
D. The incident occurred in broad daylight
4. Who was the key prosecution witness in the case?
A. A barangay tanod
B. A forensic pathologist
C. A 15-year-old boy who witnessed the stabbing
D. The police investigator
5. Which of the following correctly states the
penalty imposed by the Supreme Court?
A. Death
B. Reclusion temporal
C. Life imprisonment
D. Reclusion perpetua
6. Why did the Court consider the eyewitness credible
despite his young age?
A. He was related to the victim
B. He gave a sworn affidavit
C. His testimony was consistent and corroborated by physical
evidence
D. He had no prior convictions
7. What reason did the defense use to question the
credibility of the eyewitness?
A. The witness was under oath
B. The witness was the victim’s relative
C. The crime occurred at night and visibility was allegedly
poor
D. The witness gave inconsistent statements on motive
8. What was the victim doing just before he was
attacked?
A. Running away
B. Sitting beside the witness inside a vehicle
C. Drawing a weapon
D. Arguing with the accused
9. Which of the following damages was NOT awarded by
the Supreme Court?
A. Moral damages
B. Civil indemnity
C. Nominal damages
D. Exemplary damages
10. What was the final monetary award ordered by the
Court for exemplary damages?
A. ₱30,000
B. ₱50,000
C. ₱75,000
D. ₱100,000
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