G.R. No. 115987 August 23, 1995
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. FLORENTINO REOVEROS, accused-appellant.

FACTS

Accused-appellant Florentino Reoveros was charged with murder for the killing of Cipriano Bulfa on June 2, 1991. The information alleged that Reoveros, conspiring with two unidentified individuals, attacked and shot the victim with treachery. The prosecution’s sole eyewitness was the victim’s wife, Marivic Bulfa. She testified that on the night of the incident, she recognized appellant’s voice calling her husband. Upon looking through a small opening in their door, she saw appellant holding a long gun, accompanied by two others. After her husband asked what they wanted, appellant went to their front door, inserted a gun through an opening, and fired four shots, killing Bulfa. Appellant and his companions then threatened Marivic before fleeing.
The defense challenged Marivic’s credibility, primarily arguing that her delay of about one and a half months in reporting appellant’s identity to authorities rendered her testimony doubtful. Appellant did not testify nor present any witnesses, relying on the alleged insufficiency of the prosecution’s evidence.

ISSUE

Whether the trial court erred in convicting appellant of murder based on the eyewitness testimony of Marivic Bulfa, notwithstanding the delay in her reporting the accused’s identity.

RULING

The Supreme Court affirmed the conviction. The delay in reporting does not automatically impair a witness’s credibility, especially when satisfactorily explained. The Court cited established jurisprudence, such as People vs. Dominguez and People vs. Gamboa, which hold that delay is not fatal, particularly when witnesses are related to the victim and are intimidated. Marivic explained her initial silence was due to fear and confusion, a reasonable reaction given the direct threats against her life made by the assailants.
Furthermore, the Court found Marivic’s positive identification of appellant credible and consistent. She recognized his voice, clearly saw his face and the gun he carried under adequate illumination, and logically inferred he was the shooter when he moved to the front door and gunshots immediately followed. The trial court’s assessment of witness credibility is accorded great respect, as it is in a better position to observe demeanor. The prosecution successfully proved appellant’s guilt beyond reasonable doubt, overcoming the presumption of innocence. The qualifying circumstance of treachery was duly established, as the attack was sudden and denied the victim any chance to defend himself. The penalty of reclusion perpetua and awarded damages were affirmed.