G.R. No. 132166 May 19, 1999
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. GLENN LOTOC, JOEL DURAN, JULITO GOLONG and “BAUL,” accused, GLENN LOTOC, appellant.

FACTS

The accused, including appellant Glenn Lotoc, were charged with murder for the killing of Benedicto Mabulac. The prosecution’s case rested primarily on the eyewitness account of Cecilio Mabingnay. He testified that on the evening of March 17, 1996, he saw appellant holding the victim’s hands behind his back while his co-accused, Joel Duran and Julito Golong, successively stabbed Mabulac. After appellant released him, the victim ran but was chased by another accused, “Baul.” Mabingnay did not immediately report the incident to the police, explaining he feared for his safety. The defense presented an alibi, claiming appellant was elsewhere refrigerating fish and later helped load the wounded victim into a tricycle to be taken to the hospital.

ISSUE

The core issue is whether the testimony of a single eyewitness, Cecilio Mabingnay, is sufficient to sustain appellant’s conviction for murder beyond reasonable doubt, despite his initial delay in reporting the crime and in light of the defense of denial.

RULING

Yes, the conviction is affirmed. The Supreme Court upheld the trial court’s reliance on Mabingnay’s positive and credible identification of appellant as a direct participant. The Court reiterated the well-settled doctrine that the testimony of a single witness, if clear and convincing, is adequate for a conviction. The trial court’s assessment of witness credibility is accorded great weight and respect on appeal, as it is in a better position to evaluate testimonial demeanor. Appellant failed to show any fact of weight that the trial court overlooked. The delay in reporting the crime was sufficiently explained by the witness’s genuine fear of reprisal, which does not impair credibility but is understandable under the circumstances. The defense of denial, being inherently weak, cannot prevail over the positive testimony of a credible eyewitness. The qualifying circumstance of treachery was correctly appreciated, as the attack was sudden and the victim was rendered defenseless while being restrained by appellant, ensuring the execution of the crime without risk to the assailants.