G.R. No. L-61134 July 15, 1985
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. REYNALDO BOCASAS, accused-appellant.

FACTS

On April 3, 1978, a ping-pong game was ongoing on Samar Street, Sampaloc, Manila, between Mario Neral and another individual. Among the spectators was prosecution eyewitness Francisco Fabian. Fabian testified that he saw accused-appellant Reynaldo Bocasas, alias “Boy Puti,” together with Romeo Ayong, approach the victim from behind and stab him multiple times with kitchen knives before fleeing. The victim, Mario Neral, was rushed to the hospital but died days later from his wounds. The police investigation initially identified the assailants but they could not be located.
More than three years later, in August 1981, police learned that a certain Leonardo Giron, alias “Boy Puti,” was detained in the Quezon City Jail for robbery. Eyewitness Francisco Fabian was brought to the jail, where he positively identified the detained individual as the accused, Reynaldo Bocasas, leading to his prosecution for murder. The accused denied involvement, claiming he was merely a spectator who ran away during the commotion and later went into hiding because he heard policemen who were relatives of the victim were hunting him.

ISSUE

The core issues were: (1) whether the eyewitness testimony of Francisco Fabian was credible and sufficient to establish the accused’s identity as one of the assailants, and (2) whether the accused’s flight after the incident was indicative of guilt.

RULING

The Supreme Court affirmed the conviction. On the credibility of the eyewitness, the Court upheld the trial court’s assessment, giving great weight to Fabian’s positive identification. The Court ruled that Fabian, who was only 2.5 meters away, had a clear view of the incident. The accused’s mere denial, being self-serving negative evidence, could not prevail over the positive, straightforward testimony of a credible disinterested witness. The Court noted the accused failed to present any corroborating witness from the numerous spectators to support his denial.
On the issue of flight, the Court sustained the trial court’s conclusion that the accused’s immediate disappearance and his being found only after more than three years constituted flight evidencing a consciousness of guilt. The legal principle applied was that flight is an admission by conduct indicative of guilt. The Court also found that the killing was attended by treachery because the victim, engaged in a game, was attacked from behind and was in no position to defend himself. The concerted actions of the two assailants made them equally liable for the crime of murder. The penalty of reclusion perpetua was affirmed, but the civil indemnity was increased to P30,000.00.