G.R. No. 128551 ; July 31, 2000
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RAMIL SAMOLDE Y TAMBUNTING and ARMANDO ANDRES, accused. RAMIL SAMOLDE Y TAMBUNTING, accused-appellant.

FACTS

Accused-appellant Ramil Samolde, together with Armando Andres, was charged with Murder for the killing of Police Corporal Feliciano Nepomuceno on May 13, 1989, in Taytay, Rizal. The prosecution’s eyewitness, Ricardo Nepomuceno (the victim’s nephew), testified that he saw Samolde grab the victim from behind while Andres stabbed him, took his service firearm, and shot him three times. Ricardo claimed he recognized both assailants from a distance of 15-20 meters under light from an electric post and nearby houses. The defense presented alibi, with Samolde claiming he was at a different location watching a movie at the time of the incident.

ISSUE

The core issue is whether the prosecution proved the guilt of accused-appellant Ramil Samolde beyond reasonable doubt, particularly challenging the credibility of the lone eyewitness and the weakness of the alibi defense.

RULING

The Supreme Court affirmed the conviction. The Court found the testimony of eyewitness Ricardo Nepomuceno credible and sufficient to establish Samolde’s guilt. Ricardo had no ill motive to falsely testify, positively identified Samolde whom he had known for a long time, and gave a clear and consistent account of the incident. His proximity and the available lighting conditions made his identification reliable. The Court also ruled that the qualifying circumstance of treachery was duly proven, as the attack was sudden and from behind, rendering the victim defenseless. The defense of alibi was correctly rejected for being weak and unsubstantiated; it cannot prevail over positive identification. The trial court’s decision was affirmed with modification regarding damages, awarding an additional ₱23,800.00 as actual damages for proven funeral expenses.