People vs Lase 219 SCRA 584 Digest

People v. Lase

Offer of Compromise in Criminal Case

Facts:

1. Appellant was convicted of the murder of one Dante Huelva. Huelva was urinating on the roadside when accused appellant stabbed him in the back. This was witnessed by two people Sayson and Pangatihon. 

2. Accused-appellant interposed the defense of alibi and relied on the testimony of his principal witnesses to support his version that he was somewhere else and not at the scene of the crime at the time of the killing. 

3. During the trial, Godofreda Huelva, mother of the victim testified that accused-appellant offered to settle the case for the sum of P10,000.00. In his surrebuttal testimony, accused-appellant vaguely denied this offer of compromise. He, however, insinuated that he could offer a higher amount

RTC: The Trial court held him liable for the killing of Dante Huelva qualifying it to murder,

Issue: Whether or not the offer to settle the case should be admitted as evidence of guilt

YES. An offer of compromise by the accused may be received in evidence as an implied admission of guilt. The second paragraph of Section 27, Rule 130 of the Revised Rules of Court expressly provides that,'In criminal cases, except those involving quasi-offenses (criminal negligence) or those allowed by law to be compromised, an offer of compromise by the accused may be received in evidence as an implied admission of guilt. Murder is not among those criminal cases that can be compromised. 

Treachery was proven but not evident premeditation

The crime was committed with treachery due to the sudden and unexpected attack on the victim, who was then urinating at the side of the road, with a deadly 7-inch Batangas knife. Accused-appellant consciously adopted this mode of attack to facilitate or insure the commission of the crime without risk to himself arising from any defensive or retaliatory act on the part of the victim. Evident premeditation was not duly established by the prosecution.

As to the delay in giving the witness' statement

The failure of prosecution witness Pangantihon to immediately report the incident did not affect his credibility. His initial reluctance either due to unwillingness to be involved in or dragged into criminal investigations is understandable.