G.R. No. 101022 February 27, 1992
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. EDUARDO ANDASA alias “Eddie”, accused-appellant.

FACTS

Accused-appellant Eduardo Andasa was convicted of murder for the killing of Martin Andea. The prosecution evidence established that on the evening of May 3, 1987, during a festival dance in Barangay Bungol, Alimodian, Iloilo, the victim was drinking with a group, including the appellant, outside the dancehall. The appellant was squatting directly behind Andea. Without warning, the appellant shot the victim once in the back, causing his death. Eyewitnesses, including barangay tanods, positively identified Andasa as the assailant. The police investigation was delayed for about a month as the area was considered NPA-infested, and initial reports listed the assailant as unknown due to witnesses’ fear of reprisal. The defense presented a different version, with the appellant and two witnesses testifying that he was seated at a vendor’s stall some distance away when a gunshot from another direction felled the victim, and that he did not possess a gun.

ISSUE

Whether the trial court and the Court of Appeals erred in convicting the accused-appellant of murder based on the credibility of the prosecution witnesses.

RULING

The Supreme Court affirmed the conviction. The core issue was factual, hinging on witness credibility. The Court upheld the findings of the lower courts, emphasizing that the trial court is in the best position to assess credibility, and its findings are generally not disturbed on appeal. The appellant’s arguments—questioning the delayed police investigation and the initial “unknown” assailant report, and claiming lack of motive—were found unmeritorious. The delay and initial report were satisfactorily explained by the witnesses’ legitimate fear in an NPA-influenced area, which did not undermine their positive courtroom identification. Regarding motive, the Court reiterated the settled doctrine that where the accused is positively identified by credible eyewitnesses, proof of motive becomes inconsequential. The killing was qualified by treachery, as the appellant suddenly shot the unarmed and unsuspecting victim from behind. With no aggravating or mitigating circumstances, the proper penalty is reclusion perpetua. The decision of the Court of Appeals was affirmed in toto.