GR 118771; (January, 1996) (Digest)
G.R. No. 118771 ; January 18, 1996
People of the Philippines, plaintiff-appellee, vs. Maximo Abrenica y Tejana, accused-appellant.
FACTS
Accused-appellant Maximo Abrenica was charged with Murder for the killing of Reynaldo Mabisa and Frustrated Murder for the shooting of Ramiro Garcia, both occurring on September 11, 1991. The prosecution’s case rested primarily on the eyewitness account of the surviving victim, Ramiro Garcia. Garcia testified that while working as a stevedore on a barge in Manila, Abrenica, without any provocation, suddenly pointed a gun at him and fired, hitting him in the chest. After Garcia fell, Abrenica shot him again, pushed him into the water, and continued firing. Garcia also witnessed Abrenica shoot his co-worker, “Yoyong” (Reynaldo Mabisa), who was hit in the face and later died. Garcia positively identified Abrenica in court as the assailant. The trial court convicted Abrenica of both charges.
ISSUE
Whether the trial court erred in convicting the accused based on the alleged conflicting and unreliable testimony of the lone eyewitness, Ramiro Garcia, concerning his positive identification of Abrenica as the perpetrator.
RULING
The Supreme Court affirmed the conviction. The legal logic centered on the credibility of eyewitness identification and the presence of treachery. The Court found Garcia’s testimony to be clear, categorical, and consistent. He unequivocally pointed to Abrenica in open court as the person who shot both him and Mabisa. This positive identification, given without any noted ill motive, was afforded full faith and credit. Such direct testimony prevails over Abrenica’s defenses of denial and alibi, which are inherently weak.
Furthermore, the Court ruled that the crimes were committed with treachery (alevosia), qualifying the killing as Murder and the attack on Garcia as Frustrated Murder. The attack was sudden and unexpected, executed in a manner that ensured its execution without risk to the assailant from any defense the unarmed and unsuspecting victims could offer. This satisfied the legal definition under Article 14 of the Revised Penal Code. Applying the penalty provisions in effect at the time of the crime, the imposition of reclusion perpetua for Murder was correct. No error was found in the trial court’s assessment of the evidence.