GR 115367; (September, 1995) (Digest)
G.R. No. 115367 September 28, 1995
People of the Philippines vs. Eleuterio de Leon and Reynaldo Manayao
FACTS
Accused-appellant Eleuterio de Leon, along with co-accused Reynaldo Manayao, was charged with Murder for the ambush and killing of Marcelino Santiago on August 23, 1992, in Angat, Bulacan. The prosecution presented eyewitnesses Simon Mariano and Ramon Chavez, who testified that they saw de Leon and Manayao shoot the victim while he was driving his jeep. Mariano, who was about ten meters away, identified both accused as his townmates and described de Leon firing an Armalite rifle and Manayao a .45 caliber pistol. Chavez, approximately six meters away, also witnessed the shooting. The victim died from a single gunshot wound to the head, which the municipal health officer concluded was caused by an Armalite. The defense presented alibi, with de Leon claiming he was at a different location attending a birthday party at the time of the incident.
ISSUE
The core issue is whether the prosecution proved the guilt of accused-appellant Eleuterio de Leon beyond reasonable doubt, primarily challenging the credibility of the eyewitness identifications and the consistency of the medical evidence with the eyewitness accounts regarding the number of gunshots fired.
RULING
The Supreme Court affirmed the conviction. The Court found the testimonies of eyewitnesses Mariano and Chavez credible, consistent, and given in a straightforward manner. Their proximity to the crime scene and their immediate recognition of the accused as townmates lent reliability to their identifications. The defense of alibi was correctly rejected for being weak and unsubstantiated, especially as it failed to prove the physical impossibility for de Leon to have been at the crime scene. The Court also resolved the apparent discrepancy between the six gunshots heard by the witnesses and the single gunshot wound found on the victim. It ruled that this did not discredit the eyewitness accounts, as the number of shots fired is not an essential element of the crime of Murder. The trajectory of the fatal wound was consistent with the witnesses’ description of the attack from behind. The qualifying circumstance of treachery was sufficiently established, as the attack was sudden and from behind, ensuring the victim had no opportunity to defend himself. The Court modified the damages awarded but sustained the penalty of reclusion perpetua.