GR 112718; (March, 1996) (Digest)
G.R. No. 112718 March 29, 1996
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. VLADIMIR CANUZO Y LANDICHO, defendant-appellant.
FACTS
Accused-appellant Vladimir Canuzo was convicted of Murder for the killing of Oscar Ulitin and sentenced to reclusion perpetua. The prosecution’s case primarily rested on the testimony of a single eyewitness, Ignacio Manalo, a 77-year-old man. Manalo testified that on August 12, 1991, at around 1:00 PM, he was at a store in Batangas with the victim and Vicente Palo. The victim was sitting in front of the store when Canuzo suddenly appeared and shot him. Vicente Palo tried to wrestle the gun away from Canuzo, during which more shots were heard, before Canuzo fled. The defense challenged Manalo’s credibility, arguing his testimony was uncorroborated and inconsistent with the medico-legal report regarding the number and location of wounds. The defense also presented Virgilio Palo, the store owner, who claimed Manalo was not present at the scene.
ISSUE
Whether the trial court erred in convicting the accused based primarily on the testimony of a single eyewitness.
RULING
The Supreme Court affirmed the conviction. The testimony of a single witness, if credible and positive, is sufficient to support a conviction, and no law requires corroboration. The trial court’s assessment of witness credibility is accorded great respect, and there was no showing of abuse of discretion in its finding that Ignacio Manalo was a credible witness. His testimony withstood rigorous cross-examination, and he was shown to have no ill motive to falsely testify. The defense’s reliance on a case involving circumstantial evidence was misplaced, as this case involved positive identification. The alleged inconsistencies between Manalo’s account and the medico-legal findings were not fatal; whether the attack was frontal or from behind, it was sudden and unexpected, qualifying the killing with treachery. The defense’s alibi was weak and uncorroborated, and his flight and the presence of gunpowder on his hands further indicated guilt. The court also held that the affidavits of Vicente Palo and Alberto Marasigan were inadmissible hearsay, as the affiants were not presented for cross-examination.