G.R. No. 118168 -70 September 11, 1996
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. REYNALDO PAULE y DONATO, accused-appellant.

FACTS

Accused-appellant Reynaldo Paule was charged with Murder for the killing of Carlos Tubongbanua. The prosecution evidence established that on October 18, 1990, in Olongapo City, the victim was followed by three men, including Paule. After positioning themselves, Paule, from behind, shot the unarmed Tubongbanua twice in the head. Paule then took the victim’s gold necklace before fleeing. Witnesses identified Paule, who was later arrested at a checkpoint. A search of his uncle’s residence, based on his statement, yielded a .38 caliber revolver, ammunition, and a polo shirt matching the assailant’s description. Paule also executed an extrajudicial confession admitting he and an accomplice were hired to kill the victim for P5,000.00.
The defense presented a denial and alibi. Paule, a former NPA member, claimed he was arrested while on a bus and was mauled into giving a confession without proper counsel. He disowned the recovered items and his confession, alleging they were products of coercion. The Regional Trial Court convicted him of Murder, appreciating the qualifying circumstance of treachery. He appealed, questioning the credibility of witnesses and the admissibility of his confession.

ISSUE

The core issue is whether the prosecution proved the guilt of the accused-appellant for the crime of Murder beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction. The Court found the testimony of eyewitness Amos Manalo credible, consistent, and unwavering even under cross-examination. His positive identification of Paule as the gunman was accorded full faith and credit. The Court ruled that the extrajudicial confession, while potentially inadmissible due to procedural lapses in its custodial taking, became inconsequential. The conviction was firmly sustained by the overwhelming weight of the direct eyewitness testimony and corroborating physical evidence. The recovery of the murder weapon and the victim’s necklace from Paule, pursuant to a valid warrantless search incident to a lawful arrest, further cemented his guilt.
The killing was qualified as Murder by treachery. The attack was sudden, from behind, and directed at the victim’s head, rendering the unarmed Tubongbanua utterly defenseless. This method was consciously adopted to ensure the execution without risk to the assailants. With treachery present, the penalty of reclusion perpetua was correctly imposed. The Court deemed it unnecessary to rule on the alleged aggravating circumstances of evident premeditation and price or reward, as they would not alter the penalty. The decision of the trial court was affirmed in toto.