G.R. No. 110085 . July 6, 1999.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ANDRES R. MACUHA and DIONARIO “Diony” NAZARENO (at-large), accused, ANDRES R. MACUHA, accused-appellant.

FACTS

On June 19, 1990, at around 6:30 PM in Barangay San Antonio, Pila, Laguna, Solita Pural was herding ducks in front of the house of accused-appellant Andres R. Macuha. Her husband, Virgilio Pural, Jr., arrived. At that time, Macuha was inside his house drinking with Dionario Nazareno. Solita overheard Macuha say he wanted to kill somebody, and Nazareno handed a hunting knife to Macuha. Macuha uttered threats against Virgilio. When Virgilio turned to go home, Macuha stabbed him from behind, causing him to fall into an irrigation canal. Macuha overtook him and stabbed him again at the back. After the victim fell on his stomach, Macuha turned him over and stabbed him on the breast. Macuha and Nazareno then fled. The victim was brought to the hospital but died that same evening from multiple stab wounds, including a fatal one on the chest. Accused-appellant Macuha voluntarily surrendered to the PNP of Pila, Laguna, on October 1, 1990. He was charged with murder, convicted by the Regional Trial Court, and sentenced to reclusion perpetua and to pay indemnity. He appealed, questioning the credibility of the eyewitness, Solita Pural, the victim’s wife, and claiming self-defense. He testified that the victim drew a knife, they grappled for it, and he ran away out of fear when he heard calls for the victim’s armed relatives, denying he stabbed the victim.

ISSUE

The primary issue is the credibility of the prosecution witness, Solita Pural, and whether the accused-appellant’s claim of self-defense can prevail over her positive identification.

RULING

The Supreme Court affirmed the conviction. The testimony of Solita Pural was found credible, consistent, candid, and given in unequivocal terms. The Court held that relationship by itself does not impair a witness’s credibility; it can even make the testimony more credible as it is unnatural for a relative to accuse someone other than the real culprit. The trial court’s assessment of witness credibility is generally respected. The positive identification by an eyewitness carries greater weight than the accused’s unsubstantiated denial. Denial is a weak defense and must be substantiated by clear and convincing evidence, which accused-appellant failed to do. His claim of self-defense was untenable as he admitted grappling with the victim for a knife but failed to prove unlawful aggression on the part of the victim. The qualifying circumstance of treachery was present because the attack was sudden and from behind, giving the victim no opportunity to defend himself. The Court affirmed the penalty of reclusion perpetua and the award of P50,000.00 as civil indemnity.