GR 124666; (February, 2002) (Digest)
G.R. No. 124666 ; February 15, 2002
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RENATO SAMSON y COREA, accused-appellant.
FACTS
The prosecution’s case rested primarily on the eyewitness account of John Dexter Tuazon Daylag. He testified that in the early morning of August 28, 1994, he and the victim, Sol Homicillada, were playing darts in Parañaque when two armed men, later identified as barangay tanods Renato Samson and Marcelo Aniag, suddenly approached from behind and fired shots at them. After Sol was initially hit and fell, Samson passed close to John, whose face was illuminated by a nearby fluorescent lamp, and fired three to four more shots at Sol’s head at close range. John executed a sworn statement identifying Samson. The autopsy report confirmed the victim sustained six gunshot wounds, with one fired at very close range.
For his defense, accused-appellant Renato Samson merely denied the charges and claimed he did not know the victim or his alleged co-assailant. He suggested that the principal witness, John Daylag, was motivated by a prior personal grudge stemming from a fistfight they had in April 1994. The trial court found Samson guilty of Murder qualified by treachery and sentenced him to death, prompting this automatic review.
ISSUE
The core issue is whether the guilt of accused-appellant Renato Samson for the crime of Murder was proven beyond reasonable doubt.
RULING
The Supreme Court affirmed the conviction for Murder but modified the penalty to reclusion perpetua. The Court found the testimony of eyewitness John Daylag to be credible, positive, and consistent. His identification of Samson was reliable, as he had a clear view of the appellant’s face when he passed by at close range under sufficient illumination from a nearby light. The defense of denial and alleged ill motive of the witness could not prevail over this clear and categorical eyewitness account. The Court upheld the finding of treachery (alevosia), as the attack was sudden and from behind, rendering the victim unable to defend himself. However, the death penalty was reduced to reclusion perpetua because the qualifying circumstance of treachery was not alleged with sufficient specificity in the Information. The Court also modified the awarded damages, increasing moral damages to ₱50,000 and exemplary damages to ₱25,000 due to the presence of the aggravating circumstance.