G.R. No. L-30103. January 20, 1977.
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. BENJAMIN CUNANAN alias Ben Cunanan, alias Commander Hizon, accused-appellant.

FACTS

On August 30, 1960, Isaac Tanglao, a hacienda overseer, was killed in a rice field in Mexico, Pampanga. Three armed men in army fatigue uniforms emerged from a bamboo thicket, firing their guns. The victim’s fifteen-year-old son, Jacob, witnessed the attack. He saw his father fall while trying to flee. One of the assailants, later identified as Benjamin Cunanan, approached Isaac, kicked him, and, after a brief exchange, joined his companions in repeatedly shooting the victim. Cunanan then used the victim’s own bolo to hack him. Jacob observed Cunanan had a sharp nose, mustache, and a gold tooth.
After the killing, the three men commandeered a jeepney driven by Francisco Lingad. They told him they had killed a “Huk” and ordered him to drive. They stopped at the victim’s residence, where two alighted and confronted the victim’s widow, Ursula Pangan. They seized firearms from the house and told her they had killed her husband. Ursula positively identified Cunanan as one of the men who held her at gunpoint. Both Jacob and Ursula later identified Cunanan from a photograph shown by Constabulary agents.

ISSUE

The core issue is whether the prosecution evidence, particularly the eyewitness identifications, sufficiently proves beyond reasonable doubt that appellant Benjamin Cunanan was one of the assailants who killed Isaac Tanglao.

RULING

The Supreme Court affirmed the conviction. The legal logic rests on the credibility and consistency of the prosecution witnesses’ positive identification, which established Cunanan’s guilt to a moral certainty. Jacob Tanglao had a clear, unobstructed view of the assailants during the daylight attack and provided specific physical descriptors of Cunanan. His testimony was corroborated by the widow, Ursula Pangan, who identified Cunanan at her home shortly after the crime, and by jeepney driver Francisco Lingad’s account of transporting three armed men matching the description. Their collective narratives formed a coherent and credible story of the crime.
The Court rejected the defense of alibi and allegations of frame-up by Constabulary agents as unsubstantiated. The killing was qualified as murder by abuse of superiority, as the armed attackers exploited their manifest advantage over the unarmed and defenseless victim. The trial court correctly found that the aggravating circumstances of evident premeditation and craft were not proven. Similarly, treachery was absent because the attack began with shouts and gunfire, negating any element of surprise. With no modifying circumstances present, the penalty of reclusion perpetua was properly imposed as the medium period of the penalty for murder. The Court modified the judgment by increasing the civil indemnity to twelve thousand pesos.