People v. Arpon
G.R. No. 229859
June 10, 2019
FACTS:
The
evidence for the prosecution revealed that, at 3:00 a.m. on May 27, 2010, the
victim, Rodolfo R. Moriel (Rodolfo) and Bernardo S. Insigne (Bernardo) were
headed home walking side by side ( from Baran gay Guindaohan, Barugo, Leyte
where they attended the vespers, to Barangay Sagkahan, Carigara, Leyte where
they resided - a 30 minute-walk) when they were accosted by accused-appellant
Arpon. Using a short bladed weapon, Arpon stabbed Rodolfo on the left chest.
Rodolfo tried to run, but he was stabbed for a second time on the right chest
by Arpon until he fell to the ground. Fearing for his own life, Bernardo fled
the scene. On the same day, Bernardo went to the police accompanied by Melita
and reported the incident. Rodolfo died due to hypovolemic shock resulting from
acute blood loss caused by three multiple stab wounds - two of which were
deemed fatal. His family incurred P40,000.00 as burial and funeral expenses.
ISSUE:
Whether
or not the accused should be held liable for murder.
HELD:
No. In
order to successfully prosecute the crime of murder, the following elements
must be established: (a) that a person
was killed; (b) the accused killed him or her; ( c) the killing was attended by
any of the qualifying circumstances mentioned in Article 24853 of the Revised
Penal Code (RPC); and ( d) the killing is not parricide or infanticide. In
the instant case, Rodolfo and Bernardo were walking side by side when they were
accosted by accused-appellant who suddenly stabbed Rodolfo with a short bolo.
Both Rodolfo and Bernardo were unarmed and were totally unaware of the
impending assault from the accused-appellant. Accused-appellant's argument that
he should be acquitted since the prosecution had not established motive as to
why he would attack and kill Rodolfo does not persuade because: motive is not
an essential element of a crime and hence the prosecution need not prove the
same. As a general rule, proof of motive for the commission of the offense
charged does not show guilt and absence of proof of such motive does not
establish the innocence of the accused for the crime charged such as murder.
The history of crimes shows that murders are generally committed from motives
comparatively trivial. Crime is rarely rational. In murder, the specific intent
is to kill the victim.
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