G.R. No. 172752 ; June 18, 2008
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RODOLFO SISON, accused-appellant.

FACTS

On the evening of November 25, 1993, Bernadette dela Cruz and her siblings were inside their house in Lingayen, Pangasinan when they heard stones hitting their roof. Bernadette looked out the window and saw appellant Rodolfo Sison and Corleto Sendaydiego sitting on a nearby Pepsi stand. Their father, Bernabe dela Cruz, went outside to confront the two. Appellant suddenly drew a gun and shot Bernabe three times, hitting him in the chest and stomach. The assailants then fled. Bernabe was rushed to the hospital but died from his wounds. Multiple eyewitnesses, including Bernadette and the victim’s widow Lydia, positively identified appellant as the shooter.
Appellant was charged with Murder and violation of Presidential Decree No. 1866 (illegal possession of firearm). During trial, the defense presented appellant’s testimony, which was one of denial. He claimed he was merely present with Sendaydiego, who was the one who threw stones and later fired shots. Appellant alleged he tried to pacify Sendaydiego and hid during the incident, later advising Sendaydiego to flee. The Regional Trial Court convicted appellant of both charges, a decision affirmed with modification by the Court of Appeals.

ISSUE

The core issue is whether the prosecution proved appellant’s guilt for the crime of Murder beyond reasonable doubt.

RULING

Yes, the Supreme Court affirmed appellant’s conviction for Murder. The Court found the testimonies of the prosecution witnesses credible, consistent, and positive. The defense of denial is inherently weak and cannot prevail over the categorical and straightforward identification made by eyewitnesses who had no ill motive to falsely testify. The Court upheld the finding of treachery (alevosia), qualifying the killing to Murder. The attack was sudden and unexpected, depriving the unarmed victim of any chance to defend himself. The stoning of the house served to lure the victim out, after which he was immediately shot.
The Court modified the awarded damages, increasing the civil indemnity, moral damages, and exemplary damages in line with prevailing jurisprudence. However, the Court set aside the conviction for illegal possession of firearm. Applying the doctrine from People vs. Ladjaalam, the illegal possession charge was absorbed by the murder conviction, as the same firearm was used to commit the killing. The penalty for murder is reclusion perpetua, without eligibility for parole. The decision of the Court of Appeals was thus affirmed with modifications regarding the damages and the dismissal of the separate firearm charge.