GR 178541; (March, 2008) (Digest)
G.R. No. 178541 ; March 27, 2008
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. ANGELO ZETA, Accused-Appellant.
FACTS
Accused-appellant Angelo Zeta and his wife Petronilla were charged with the murder of Ramon Garcia. The prosecution evidence established that in the early morning of October 28, 1995, the couple, after inquiring about Ramon’s address, proceeded to his house in Quezon City. Petronilla called for Ramon to come out. When Ramon descended the stairs, appellant suddenly entered the house and shot him multiple times with a .45 caliber pistol, causing his death. Eyewitness Aleine Mercado, who was inside the house, saw the shooting. Other witnesses, who were drinking nearby, heard the gunshots and saw appellant and Petronilla hastily leave the scene afterwards.
Appellant and Petronilla were apprehended the next day due to a separate incident involving an unlicensed firearm. Ballistic examination later confirmed that the bullet extracted from the victim’s body matched the pistol seized from appellant. The defense presented alibi, claiming appellant was elsewhere at the time of the shooting, and denial, asserting the evidence was fabricated.
ISSUE
The core issue is whether the prosecution proved appellant’s guilt for the crime of murder beyond reasonable doubt.
RULING
The Supreme Court affirmed the conviction. The Court found the positive identification by eyewitness Aleine Mercado to be credible, consistent, and categorical. She had a clear view of the incident inside the well-lit house and had no motive to falsely testify. Her testimony was corroborated by other witnesses who placed the appellant at the scene before and immediately after the shooting. The defense of alibi and denial cannot prevail over this positive identification.
Regarding the qualifying circumstance, the Court upheld the presence of treachery. The attack was sudden and unexpected, giving the unarmed victim, who had just been roused from sleep, no opportunity to defend himself or repel the assault. The manner of execution—shooting the victim as he descended the stairs—directly and specifically ensured the execution of the crime without risk to the appellant. The Court modified the damages awarded, increasing civil indemnity and granting moral and exemplary damages, but found no evidence to support actual damages and loss of earning capacity. The conviction for murder was thus affirmed with modifications to the civil liability.