G.R. No. L-72318 April 30, 1987
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ROLLY ANQUILLANO alias DAGOL, accused-appellant.

FACTS

The accused-appellant, Rolly Anquillano, was convicted of the complex crime of murder with serious physical injuries and sentenced to death. The prosecution’s case rested primarily on the eyewitness account of Miguel Burton. On November 10, 1983, Burton was driving a motorcycle with Manuel Sequerra as his backrider when they were ambushed on a road in La Paz, Abra. A shotgun blast hit both men, causing Sequerra to fall dead and Burton to sustain a wound. Burton stood up and saw Anquillano standing about ten meters away, looking at him. Burton then fled on his motorcycle to report the incident.
Anquillano presented an alibi, testifying that he was harvesting rice in Ticub, a place only about two hundred meters from the crime scene in Soot, at the time of the shooting. He was corroborated by one witness, Belma Talingdan. Anquillano explained that he disappeared after the incident out of fear of being implicated. The prosecution established a possible motive, tracing it to a prior incident where Sequerra, an ex-convict, had chased Anquillano, causing him humiliation.

ISSUE

The core issue is whether the trial court erred in convicting Anquillano based on the identification by the lone eyewitness, rejecting his alibi and finding the crime to be a complex one.

RULING

The Supreme Court affirmed the conviction but modified the penalty and civil liability. The Court upheld the trial court’s assessment of credibility, finding no reason for Burton to falsely testify. His identification was deemed reliable, made in broad daylight at a close distance. The defense of alibi was correctly rejected as inherently weak and rendered especially ineffective by the proximity of the alleged location to the crime scene; the 200-meter distance could be traversed quickly.
The Court agreed with the trial court’s characterization of the offense. The killing of Sequerra constituted murder, qualified by treachery and evident premeditation. However, regarding Burton, the Court sustained the reduction of the charge from frustrated murder to less serious physical injuries. The lack of intent to kill Burton was inferred from Anquillano’s inaction after the initial blast, despite having the opportunity to finish off the wounded witness. Consequently, the single act produced the complex crime of murder with less serious physical injuries under Article 48 of the Revised Penal Code.
The penalty for the more serious offense (murder) at the time was death. However, pursuant to the 1987 Constitution prohibiting the death penalty, the sentence was reduced to reclusion perpetua (life imprisonment). The civil indemnity of P30,000.00 was affirmed, with an additional P5,000.00 awarded for proven funeral expenses. The judgment of the lower court was thus affirmed with modifications.