G.R. No. 121778 September 4, 1997
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. AARON BIONAT, accused-appellant.

FACTS

An Information was filed on July 15, 1987, charging Aaron Bionat with Murder for the killing of Ernesto Romay on August 12, 1985, in Sitio Asuncion, Barangay Naci, Surallah, South Cotabato. The accused was alleged to have acted with four unknown companions, armed with firearms, and with treachery, evident premeditation, cruelty, and abuse of strength. They were said to have taken Romay from his house, brought him about seventy meters away, and stabbed him, inflicting ten wounds which caused his death. The accused was arrested on February 24, 1994, after the case was archived. He posted bail and pleaded not guilty.
The prosecution presented the victim’s widow, Myrna Romay, and son, Joseph Romay. They testified that at around 10:00 p.m. on August 12, 1985, five men, including the accused, entered their house. Two were already inside, and three were below. The accused pointed a gun at Myrna. The men tied Ernesto Romay’s hands behind his back with a string, took him from the house, and later he was found dead. Myrna recognized the accused because he was wearing a distinctive black sweatshirt and a “tubaw” (Muslim neckerchief), and he was illuminated by a kerosene lamp about two feet away from her. She saw him again on October 13, 1985, when he escorted a tractor that was disc-harrowing a two-hectare farm she and her husband were cultivating, which was subject to a land conflict with a certain Terry Escovidal. Joseph Romay corroborated his mother’s testimony, identifying the accused as one of the men who tied and took his father.
The defense presented an alibi. The accused, a member of the Integrated Civil Home Defense Forces (ICHDF), testified he was at his house in Surallah at the time of the incident and never left. He stated he went to Sara, Iloilo, in 1987 and returned in November 1993. He admitted escorting Terry Escovidal to disc-harrow a farm on October 13, 1985, which was when he first saw Myrna Romay. He denied filing a motion on March 7, 1994, wherein he allegedly offered to execute an affidavit implicating others in the killing in exchange for an affidavit of desistance. Defense witnesses (his wife, brother-in-law, and aunt) corroborated his alibi.
The Regional Trial Court convicted the accused of Murder, qualified by treachery, and sentenced him to reclusion perpetua. The court gave credence to the positive identification by the prosecution witnesses and rejected the alibi.

ISSUE

The main issue is whether the prosecution proved the guilt of the accused beyond reasonable doubt, specifically concerning the credibility of the witnesses and the validity of the accused’s alibi.

RULING

The Supreme Court AFFIRMED the conviction. The Court held that the positive identification of the accused by the prosecution witnesses, who had no improper motive to testify falsely, prevailed over the alibi and denial of the accused. The witnesses had a clear view of the accused inside their well-lit house at close range. The delay in reporting the crime was sufficiently explained by the witnesses’ need to verify the accused’s identity and their fear. The Court found no reason to disturb the trial court’s findings on credibility, as it is in the best position to observe the witnesses’ demeanor. The qualifying circumstance of treachery was properly appreciated because the attack was sudden, ensuring the victim had no chance to defend himself. The Court dismissed the appeal and affirmed the trial court’s decision in toto.