G.R. No. 104994 February 13, 1995
People of the Philippines, plaintiff-appellee, vs. Wilfredo Morales, accused-appellant.

FACTS

Accused-appellant Wilfredo Morales was charged with murder for the killing of Rogelio Lodo on December 3, 1987, in Mandaluyong, Metro Manila. The prosecution presented two eyewitnesses: Carmelita Legaspi, the victim’s sister, and Rebecca Maraya, the victim’s cousin. Legaspi testified that she saw appellant, armed with a short firearm, approach Rogelio Lodo, who was lying on a table, and shoot him twice without warning. The first shot hit the victim’s right thigh, causing him to fall, and the second shot hit his body. Appellant then pursued the victim as he tried to flee. After the shooting, appellant threatened Legaspi. Maraya corroborated the testimony, stating she saw appellant shoot her cousin from a distance of about five meters, with light coming from the victim’s house illuminating the scene. The victim died from hemorrhagic shock due to the gunshot wounds. The defense presented Matilde Labampa, who testified she heard shots and saw a man in a black t-shirt running away, but she could not identify his face. Appellant himself denied the accusation, claiming he was in Dasmariñas, Cavite, working as a construction worker from November 15, 1987, to January 1988, but could not provide details of his employers or the specific locations. The trial court convicted appellant of murder qualified by treachery and sentenced him to reclusion perpetua.

ISSUE

Whether the trial court erred in finding appellant guilty of murder based on the testimonies of the prosecution witnesses.

RULING

The Supreme Court affirmed the trial court’s judgment. The Court held that the positive identification of appellant by the prosecution witnesses, who were relatives of the victim, was credible and sufficient to prove his guilt beyond reasonable doubt. The relationship of the witnesses to the victim does not impair their credibility, especially in the absence of any improper motive. The trial court’s assessment of witness credibility is accorded great respect. Appellant’s defense of alibi and denial cannot prevail over the positive identification, as he failed to prove it was physically impossible for him to be at the crime scene and his claims were uncorroborated. The killing was characterized by treachery, qualifying it as murder. The alleged aggravating circumstances of evident premeditation and abuse of superior strength were not proven. The penalty of reclusion perpetua was affirmed.