G.R. No. 107802 July 31, 1997
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. JASON NAREDO @ JERRY and ESTELITO ESEO @ ADO, accused, JASON NAREDO @ JERRY, accused-appellant.

FACTS

On October 19, 1991, Bayani Sumadsad and his cousin Delfin Talavera attended a wedding party at a house in Barangay Santiago, San Pablo City. Accused-appellant Jason Naredo and Estelito Eseo were also present. After midnight, a drunk Sumadsad sat resting his head on a fallen coconut tree. Talavera, who had gone to a nearby store to buy cigarettes, witnessed from about seven meters away as Naredo and Eseo, without any altercation, suddenly stabbed Sumadsad. Naredo used a 4-edged knife and Eseo used a bladed instrument for shaving carabaos, and they took turns striking the victim. Talavera was shocked and afraid, and did not immediately call for help. Sumadsad suffered ten stab and hack wounds, three of which were fatal. Only Naredo was apprehended; Eseo remained at large. Naredo denied involvement, claiming he was at the party but that Eseo alone killed Sumadsad and later forced him at knife-point to flee. He sought refuge with his employer, Ludovico Cabrera, who testified that Naredo returned on October 21 and mentioned a companion who had killed someone. The trial court found Naredo guilty of murder, citing conspiracy and treachery, as the attack was sudden and the victim was drunk and defenseless. Naredo appealed, challenging the credibility of the eyewitness.

ISSUE

Whether the trial court erred in convicting accused-appellant Jason Naredo of murder based on the testimony of prosecution witness Delfin Talavera, and whether his guilt was proven beyond reasonable doubt.

RULING

The Supreme Court affirmed the trial court’s decision. The positive identification by eyewitness Delfin Talavera, who had no motive to falsely testify, was deemed credible. The Court found no error in the trial court’s assessment of Talavera’s credibility, noting that his failure to immediately help his cousin or shout for help was a natural reaction to a shocking event, especially given his young age. The partial obstruction of view by an “aratiles” fence and Talavera’s earlier consumption of alcohol did not impair his ability to recognize the assailants, whom he had known beforehand. Naredo’s defense of alibi was rejected as it was contradicted by his own testimony and his witness’s account. His flight with Eseo after the incident indicated conspiracy. The sudden attack on a drunk and sleeping victim constituted treachery, qualifying the killing as murder. The penalty of reclusion perpetua and an indemnity of P50,000 to the victim’s heirs were upheld.