G.R. No. 100880 December 16, 1992
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. LEONARDO CLAUDIO, accused-appellant.

FACTS

The accused-appellant, Leonardo Claudio, together with two companions, invited the victim, Freddie Flores, for a stroll at the Malibay Plaza on the evening of December 2, 1986. Leonida Flores, the victim’s mother, asked her nephew, Gerardo Unawa, to follow them. At the plaza, Gerardo Unawa witnessed the appellant, from behind and without warning, hit Freddie Flores on the head with a lead pipe while the victim was conversing with one of the companions. The victim was rushed to the hospital where, in the presence of his mother and sister, he identified the appellant as his assailant and expressed consciousness of his impending death. Freddie Flores died on December 9, 1986. The Regional Trial Court convicted the appellant of Murder. On appeal, the Court of Appeals affirmed the conviction but modified the penalty to reclusion perpetua and increased the civil indemnity to P50,000.00. Pursuant to the Rules of Court, the Court of Appeals certified the case to the Supreme Court for final review.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of the accused-appellant for Murder.

RULING

The Supreme Court affirmed the decision of the Court of Appeals. The Court held that the conviction was based on credible evidence, including the positive eyewitness account of Gerardo Unawa, who clearly identified the appellant as the perpetrator, and the dying declaration of the victim to his mother and sister. The relationship of the prosecution witnesses to the victim does not impair their credibility absent evidence of bias. The defense of alibi was correctly rejected as it is inherently weak against positive identification. The killing was qualified by treachery because the victim was attacked from behind without any warning while he was engaged in conversation. The penalty of reclusion perpetua and the award of P50,000.00 as civil indemnity to the heirs of the victim were upheld.